THOMAS, Circuit Judge:
Bobby Welch and his wife Kathleen Newman appeal the tax court's judgment upholding the assessment of federal income tax deficiencies by the Commissioner of Internal Revenue ("Commissioner"). We have jurisdiction under 26 U.S.C. § 7482, and we affirm.
I
On August 16, 1995, the Commissioner sent Welch and his wife a statutory notice of deficiency determining deficiencies in their federal income tax for the years 1986 through...
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