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JENKINS v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 27139-11, 28712-11.

T.C. Memo. 2021-54

RANDY JENKINS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. IRA W. GENTRY, JR., AND LYNN M. GENTRY, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 10, 2021.

Attorney(s) appearing for the Case

Randy Jenkins, pro se in docket No. 27139-11.

Ira W. Gentry, Jr., and Lynn M. Gentry, pro sese in docket No. 28712-11.

Michael W. Lloyd and Doreen Marie Susi , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

In 1772 Yves-Joseph de Kerguelen-Trémarec was commissioned by King Louis XVI to sail into the Southern Ocean in search of Terra Australis. He found instead a small archipelago almost three thousand miles off the southern tip of Africa, inhabited only by wildlife and battered by...

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