TATEL, Circuit Judge:
This case concerns Marc and Anne Barnes's joint income-tax return for fiscal year 2003. That year was a busy one for the Barneses, who at the time owned or were involved with several different restaurant, nightclub, and event-promotion businesses. Relevant here, they held a partial ownership stake in an S corporation called "Whitney Restaurants," and they also ran an unincorporated event-promotion sole proprietorship.
The Barneses' 2003...
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