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PARKS v. COMMISSIONER

Docket Nos. 7043-07, 7093-07.

145 T.C. 278 (2015)

LOREN E. PARKS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. PARKS FOUNDATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 17, 2015.

Attorney(s) appearing for the Case

Kevin O'Connell, Steven B. Hval, and Tara Lawrence, for petitioners.

Mark Alan Weiner, for respondent.

OPINION

These cases were consolidated for trial, briefing, and opinion. Respondent determined excise tax deficiencies for petitioner Loren E. Parks and petitioner Parks Foundation (Foundation) as summarized in the following tables.1

Mr. Parks, Docket No. 7043-07

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