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MENARD, INC. v. COMMISSIONER

Nos. 673-02, 674-02.

130 T.C. 54 (2008)

MENARD, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT JOHN R. MENARD, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 19, 2008.

Attorney(s) appearing for the Case

Robert E. Dallman, Vincent J. Beres, and Robert J. Misey, Jr., for petitioners.

Christa A. Gruber, J. Paul Knap, and Michael Calabrese, for respondent.

SUPPLEMENTAL OPINION

MARVEL, Judge:

This matter is before the Court on petitioners' objection to respondent's proposed Rule 1551 computations submitted in response to our holdings in Menard, Inc. v. Commissioner, T.C. Memo. 2004-207 (Menard I), and Menard, Inc. v. Commissioner, T.C. Memo. 2005-3 (Menard II). As discussed in greater detail below, in Menard I we held...

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