MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge:
These cases have been consolidated for trial, briefing, and opinion. All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. In docket No. 5220-95, respondent issued a notice of final S corporation administrative adjustment (FSAA) to Douglas J. Von Allmen, tax matters...
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