BARNETTE v. COMMISSIONER

Docket Nos. 16906-82, 22809-82, 535-85, 620-85, 29224-85, 355-88, 3282-88, 3283-88, 3285-88, 11681-88, 11682-88, 17821-88.

64 T.C.M. 998 (1992)

T.C. Memo. 1992-595

Larry D. Barnette and Kathleen C. Barnette, et al. v. Commissioner.

United States Tax Court.

Filed October 5, 1992.


Attorney(s) appearing for the Case

John Harllee, Jr., One Thomas Circle, N.W., Washington, D.C., for petitioners Larry D. Barnette, Allied Management Corp., Janet L. Barnette and Leo David Barnette, Trevor W. Swett III, Richard E. Timbie, and Jill R. Shellow, One Thomas Circle, N.W., Washington, D.C., for petitioner Kathleen C. Barnette. John F. Dean, Bobby D. Burns, and Eli J. Dicker, for the respondent.


Supplemental Memorandum Opinion

KÖRNER, Judge:

The instant consolidated cases were tried at a Special Session of the Court sitting in Jacksonville, Florida, in April of 1991. The trial consumed about a week, and the record amassed was large. After trial, and after extensive briefing, the Court rendered its Opinion herein at the end of June 1992, T.C. Memo. 1992-371.

In its Opinion, the Court identified and...

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