John F. And Tracy L. Barford, Marcus R. Messman, Davis W. Messman, and Stephen A. Messman v. Commissioner of Internal Revenue

COFFEY, Circuit Judge.

In June 1991, after a multi-year investigation, the Commissioner of Internal Revenue (“Commissioner”) issued notices of deficiency of more than half a million dollars to each of the taxpayer-appellants. The notices stated that the taxpayers were liable for additional tax because 1) they undervalued stock they received, and 2) they avoided interest income on loan transactions. The taxpayers contested the notices of deficiency and requested a trial. Shortly before trial, the Commissioner reached a settlement with the taxpayers on the issue of the valuation of the stock,…