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liable for any additions to tax or penalties. For purposes of
clarity, after a brief general background and overview of
applicable law, each of the issues submitted for our
consideration is set forth below with separate background and
discussion.
General Background
Some of the facts have been stipulated and are so found.
The stipulation of facts, first supplemental stipulation of
facts, stipulations of agreed issues, stipulation of settled
issues, and the attached exhibits are incorporated herein by this
reference. Petitioners, John A. Rowe (Mr. Rowe) and Donna L.
Rowe (hereinafter petitioner), resided in Florida at the time
they filed their petitions.
Mr. Rowe graduated from the University of Tennessee in 1969
with a degree in dental science. Thereafter, he attended the
University of Tennessee Dental School and received a degree in
dental surgery in 1972 and a degree in oral surgery in 1975.
Petitioner graduated from the University of Tennessee in 1971
with a degree qualifying her as a registered dental hygienist.
Petitioners were married in Kingsport, Tennessee, on June 27,
1971, and they had two children during their marriage,
Christopher and Elizabeth.
From 1971 to 1977, petitioners lived in Memphis, Tennessee,
where Mr. Rowe conducted an oral surgery practice. From 1977 to
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