PRADO, Circuit Judge:
Osvaldo Rodriguez and Ana M. Rodriguez ("Appellants") challenge a determination of tax deficiency made by the IRS. The IRS determined that, for 2003 and 2004, the gross income Appellants reported based on their ownership of a controlled foreign corporation should have been taxed at the rate of Appellants' ordinary income rather than the lower tax rate Appellants had claimed. Appellants challenged the IRS's determination before the Tax Court and...
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