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UNITED STATES COURT OF APPEALS

TENTH CIRCUIT


JOHN W. CONNELLY and PHYLLIS M. CONNELLY,

Petitioners - Appellants,

v.

COMMISSIONER OF INTERNAL REVENUE,

Respondent - Appellee.


WILLIAM A. JACOBS and ANN M. JACOBS,

Petitioners - Appellants,

v.

COMMISSIONER OF INTERNAL REVENUE,

Respondent - Appellee.

No. 00-9011

(U.S. Tx.Ct.)

(T.C.No. 627-98)

No. 00-9012

(U.S. Tx.Ct.)

(T.C. No. 626-98)

ORDER AND JUDGMENT(*)

Before MURPHY, HALL(2), and PORFILIO, Circuit Judges.

After reviewing the briefs of the parties and the record below, and having had the benefit of oral argument, we conclude that the tax court did not err. We therefore affirm the judgment of the tax court on the basis of that court's opinion.

Entered for the Court

Cynthia Holcomb Hall

Circuit Judge


FOOTNOTES
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*. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. This court generally disfavors the citation of orders and judgments; nevertheless, an order and judgment may be cited under the terms and conditions of 10th Cir. R. 36.3.

2.The Honorable Cynthia Holcomb Hall, Circuit Judge, United States Court of Appeals for the Ninth Circuit, sitting by designation.


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