KÓRNER, Judge: I respectfully dissent. The Eighth Circuit did not remand this case to us for any purpose except to explain the basis for our first opinion herein. Borchers v. Commissioner, T.C. Memo. 1988-349 , vacated and remanded <a href="/opinion/532105/richard-j-borchers-and-jane-e-borchers-v-commissioner-of-internal/" aria-de…
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