OWENS, Chief Judge:
FACTUAL BACKGROUND
The Internal Revenue Service (IRS) conducted an extensive examination of plaintiffs' tax returns and determined tax deficiencies for each of the plaintiffs. The IRS made determinations with respect to Horton Homes, Inc. (Horton Homes) for the taxable years ending August 31, 1978, through August 31, 1982, inclusive. The IRS also made determinations with respect to plaintiffs N.D. Horton, Sr. and Maude Horton on their...
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