Reena Raggi, Circuit Judge:
At issue on this appeal is a decision of the United States Tax Court (Kathleen Kerrigan, Judge), upholding tax deficiencies noticed by respondent Commissioner for tax year 2008 against (1) petitioners, James Benenson, Jr. ("Benenson, Jr.") and his wife Sharen Benenson; (2) petitioners' adult sons, James Benenson...
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