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EVANS v. COMMISSIONER

Docket No. 9072-86.

61 T.C.M. 2917 (1991)

T.C. Memo. 1991-272

John S. Evans and Sue A. Evans v. Commissioner.

United States Tax Court.

Filed June 13, 1991.

Attorney(s) appearing for the Case

Walter J. Rockler and Richard L. Hubbard, for the petitioners. Elizabeth P. Flores, for the respondent.

Supplemental Memorandum Opinion

TANNENWALD, Judge:

The present proceeding is a result of the reversal by the Court of Appeals for the Eighth Circuit ([90-2 USTC ¶ 50,387] 908 F.2d 369 (8th Cir. 1990)) of our prior opinion in Evans v. Commissioner [Dec. 45,097(M)], T.C. Memo. 1988-468. After concessions, the issues remaining for decision are: (1) Whether the underlying transactions...

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