PER CURIAM:
The Commissioner of Internal Revenue ("Commissioner") examined the Pecks' income tax returns for calendar years 1974, 1975, and 1976. The Commissioner issued notices of deficiency for each tax year, disallowing deductions for rent paid by the Pecks to Peck Leasing, Ltd. ("Leasing"), a corporation controlled by the Taxpayers. The Tax Court rejected the complete disallowance of the rental deduction but held that the rental deduction was excessive. It reduced...
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