EUGENE A. WRIGHT, Circuit Judge: This case requires us to apply collateral estoppel principles in the tax context. The taxpayers, Donald and Judith Peck, entered into a 30-year lease of real property in 1974 from their controlled corporation. The lease terms did not change for the first five years. In a prior action, the Tax Court found that the Pecks’ rent deductions under the lease for 1974, 1975 and 1976 must be reduced b…
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