ALARCÓN, Circuit Judge.
Stanley T. Johnson and his present wife, Constance Johnson ("Appellants"), appeal from the United States Tax Court's decision that there is a deficiency in income tax due from them for the taxable year 1997. The court has jurisdiction pursuant to 26 U.S.C. § 7482. The gravamen of Appellants' argument is that Internal Revenue Code ("I.R.C.") § 71, as amended in 1984 ("new § 71" or the "new law"), should apply to Mr. Johnson...
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