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SCHRUM v. COMMISSIONER

Docket No. 4859-91.

69 T.C.M. 2062 (1995)

T.C. Memo. 1995-103

Jake Z. Schrum and Ruby E. Schrum, Dannie L. Schrum and Jeanette V. Schrum, and Donald L. Moore and Judith A. Moore v. Commissioner.

United States Tax Court.

Filed March 13, 1995.

Attorney(s) appearing for the Case

Donald L. Moore, for the petitioners. Scott Anderson, for the respondent.

Supplemental Memorandum Opinion

WELLS, Judge:

The instant case is before us on remand from the United States Court of Appeals for the Fourth Circuit. In our prior Memorandum Opinion [Dec. 48,940(M)], T.C. Memo. 1993-124, affd. in part and vacated and remanded in part [94-2 USTC ¶ 50,451] 33 F.3d 426 (4th Cir. 1994), we upheld respondent's determination because petitioners had failed...

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