Petitioners-Appellants, Bruce and Sherilyn S. Gunkle, husband and wife (together, the Gunkles), appeal the judgment of the United States Tax Court (Tax Court) rendered pursuant to Section 7483 of the Internal Revenue Code (I.R.C.). They seek reversal of that judgment, which sustained the determination of Respondent-Appellee, the Commissioner of Internal Revenue (Commissioner), that the Gunkles had an...
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