EUGENE A. WRIGHT, Circuit Judge:
Following a program developed by the American Law Association (ALA), the Zmudas set up three foreign trusts to avoid taxes on the income from properties in the United States. The Tax Court found that these trusts were shams, disallowed certain deductions, and assessed civil penalties.
The petitioners complain that their due process rights were violated by lack of sufficient notice that they should defend the trusts against...
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