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RODRIGUEZ v. COMMISSIONER

Docket No. 13909-08.

137 T.C. 174 (2011)

OSVALDO AND ANA M. RODRIGUEZ, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 7, 2011.

Attorney(s) appearing for the Case

Patrick R. Gordon and Juan H. Gil II , for petitioners.

Roberta L. Shumway , for respondent.

OPINION

THORNTON, Judge:

Respondent determined deficiencies of $316,950 and $295,530 in petitioners' Federal income taxes for taxable years 2003 and 2004, respectively. The issue for decision is whether amounts included in petitioners' gross income pursuant to sections 951(a)(1)(B) and 9561 with respect to their controlled foreign corporation's investments in U.S. property (for brevity, section 951 inclusions) constitute...

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