Before: BATCHELDER, GRIFFIN, and WHITE, Circuit Judges.
HELENE N. WHITE, Circuit Judge.
Petitioners-appellants John J. Machacek, Jr. (John Machacek) and Marianne Machacek (together, the Machaceks), a married couple, were the sole shareholders of John J. Machacek, Jr., Inc. (Machacek, Inc.), a corporation organized under Subchapter S of the Internal Revenue Code (an S corporation). John...
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