- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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