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Section references are to the Internal Revenue Code. Unless
otherwise indicated, Rule references are to the Tax Court Rules
of Practice and Procedure.
I. FINDINGS OF FACT
A. Petitioners
Petitioners were married and lived in Gay, Georgia, when
they filed their petition.2 In 1993, the population of Gay was
about 125.
1. Edward Brockenbrough
Petitioner Edward Brockenbrough (Mr. Brockenbrough) was born
in 1935. His paternal and maternal grandparents operated
dairies. His parents were airplane pilots. They owned about 300
acres of land on which they operated an airport and a farm with
cattle, horses, and pigs. Mr. Brockenbrough milked cows every
day for 7 years when he was a child. Mr. Brockenbrough took one
agricultural course and was a member of the Future Farmers of
America when he was in high school. He graduated from college
with a degree in economics. He left home after he graduated from
college.
Mr. Brockenbrough began working as a pilot for Delta
Airlines (Delta) when he was 28 years old. Federal law required
him to retire on August 8, 1995, when he reached the age of 60.
He had worked for Delta 31 years when he retired. For the 15
2 Petitioner Edward Brockenbrough died after the trial was
held in this case.
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