T.C. Memo. 2004-64
UNITED STATES TAX COURT
ROBERT GRIFFIN AND JULIA GRIFFIN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 7315-00. Filed March 11, 2004.
James Allen Brown, for petitioners.
H. Elizabeth Downs, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
THORNTON, Judge: This case is before this Court on remand
from the U.S. Court of Appeals for the Eighth Circuit for further
consideration consistent with its opinion in Griffin v.
Commissioner, 315 F.3d 1017 (8th Cir. 2003), vacating and
* This Memorandum Opinion supplements our previously filed
opinion in Griffin v. Commissioner, T.C. Memo. 2002-6, vacated
and remanded 315 F.3d 1017 (8th Cir. 2003).
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