LEAVY, Circuit Judge:
In this case we are called upon to review a decision of the United States Tax Court ("Tax Court") upholding the government's assessment of various taxes and penalties against a husband, his wife, and their Delaware holding company formerly operating in the United States Virgin Islands ("USVI"). For the reasons which follow, we affirm the imposition of capital gains taxes against the husband and wife and the Delaware company, but reverse the assessed...
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