SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
This matter is before the Court on remand from the Court of Appeals for the Ninth Circuit in Bybee v. Commissioner, 29 F.3d 630 (9th Cir. 1994), affg. in part, vacating and remanding in part without published opinion [Dec. 49,062(M)]
Unless otherwise indicated, all section references are to the Internal Revenue Code...
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