Rehearing and Rehearing En Banc Denied September 10, 1991.
CUMMINGS, Circuit Judge.
Ben Franklin once said that in this world, nothing can be said to be certain but death and taxes. This case calls for a variation on the old adage. Add some unfortunate mistakes by a well-meaning lawyer to the picture and the saying becomes: nothing can be said to be certain but death and higher taxes. Here's what happened. In April 1989 the Tax Court determined that...
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