Nos. 01-17249, 01-17251, 01-17253, 01-17255 to 01-17257, 07-12866 to 07-12871.

522 F.3d 1229 (2008)

Claude M. BALLARD, Mary B. Ballard, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

April 7, 2008.

Attorney(s) appearing for the Case

Danny S. Ashby, Robert Edwin Davis, Kirkpatrick & Lockhart Preston Gates, Ellis, Vester T. Hughes, Jr., Hughes & Luce, L.L.P., David J. Schenck, Jones Day, Dallas, TX, Steven Spencer Brown, Royal B. Martin, Jr., Martin, Brown & Sullivan, Ltd., Chicago, IL, for Petitioners-Appellants.

Joan I. Oppenheimer, Steven W. Parks, Kenneth L. Greene, U.S. Dept. of Justice, App. Tax Div., Washington, DC, for Respondent-Appellee.

Before HULL, FAY and GIBSON, Circuit Judges.

FAY, Circuit Judge:

The question presented in this appeal is simply whether the Tax Court Judge reviewing the report of the Special Trial Judge gave due regard to the factfindings of the trial judge.1 That is the only thing simple about this case.

I. Overview

Claude M. Ballard and his wife, Mary B. Ballard,2 appeal the judgment of the U.S. Tax Court that they fraudulently failed to...

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