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BROZ v. COMMISSIONER

Docket No. 21629-06.

137 T.C. 25 (2011)

ROBERT AND KIMBERLY BROZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed July 7, 2011.

Attorney(s) appearing for the Case

Stephen W. Feldman and Eric T. Weiss, for petitioners.

Meso T. Hammoud, Elizabeth Rebecca Edberg, and Steven G. Cappellino, for respondent.

KROUPA, Judge:

Respondent determined over $16 million of deficiencies1 in petitioners' Federal income tax for 1996, 1998, 1999, 2000 and 2001 (the years at issue).

In this report we decide whether RFB Cellular, Inc. (RFB), an S corporation petitioners wholly owned, is entitled to certain depreciation deductions for wireless cellular equipment. Specifically, we must determine whether petitioners properly classified antenna...

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