MEMORANDUM FINDINGS OF FACT AND OPINION
HOLMES, Judge.
In 1999 and 2000, Ulysses Lee was a full-time employee of the IRS; his brother, Kai, worked as a doctor and professor and ran several other businesses. One of these businesses was Lee Brothers Investments, a real estate investment partnership that Kai and Ulysses ran together and which owned a house and two small apartment buildings. In 1999 and 2000, Lee Brothers Investments and the brothers' other...
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