Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
These cases were consolidated for purposes of trial, briefing, and opinion. Appendix A sets forth petitioners by name and docket numbers, the tax years involved, the deficiencies for each year, and the place of residence of each individual petitioner. Each of the petitions includes, among other issues, the common issue of the tax consequences of the investment by petitioners in video tapes with religious...
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