MILAN D. SMITH, JR., Circuit Judge: Petitioner-Appellant James Sparkman appeals the decision of the Tax Court upholding the Commissioner’s notice of deficiency with respect to tax years 1996 through 2000. See Sparkman v. Comm’r, T.C. Memo 2005-136 (2005). He objects to the Tax Court’s ruling that one of his business entit…
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