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ARKANSAS OIL AND GAS, INC. v. C.I.R.

Nos. 96-3024 to 96-3026.

114 F.3d 795 (1997)

ARKANSAS OIL AND GAS, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Dale S. BRADEN, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. ARKANSAS LEASING SERVICE, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided June 11, 1997.

Attorney(s) appearing for the Case

James Allen Brown, argued, Little Rock, AR, for appellants.

Michelle B. O'Connor, U.S. Department of Justice, Washington, DC, argued (Gary D. Gray, Robert L. Baker, on the brief), for appellee.

Before LOKEN, JOHN R. GIBSON, and MAGILL, Circuit Judges.

MAGILL, Circuit Judge.

The Commissioner of the Internal Revenue Service (Commissioner) issued notices of federal income tax deficiencies and penalties to Arkansas Oil & Gas, Inc. (Arkansas Oil & Gas), Arkansas Leasing Service, Inc. (Arkansas Leasing), and Dale S. Braden (collectively, the taxpayers). Braden, an attorney who specializes in oil and gas matters, is the sole stockholder of both Arkansas Oil & Gas and Arkansas Leasing. Each of the taxpayers...

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