- 10 -
97 T.C. 339, 345 (1991). The situation is not an
unfamiliar one, and has been before us in a variety of
other circumstances. Cf., e.g., White v. Commissioner,
72 T.C. 1126, 1130-1134 (1979); Hosking v.
Commissioner, 62 T.C. 635, 642-644 (1974); and a number
of memorandum opinions cited in Berry v. Commissioner,
supra at 345 n.7.
Id. at 480.
Since, as we have already concluded above, neither Barry nor
Shelley is entitled to a refund in these cases,
Decisions will be entered
for respondent.
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