Beecher Cir

I. FACTS

A review of the record reveals the following undisputed material facts.

Gary Beecher and Dolores Beecher are husband and wife. Gary Beecher wholly owns Cal Interiors, Inc., a “C” corpora- tion, that engages in the business of repairing automobile inte- riors. Dolores Beecher wholly owns S&C Dent Corp., also a “C” corporation, that engages in the business of removing dents from automobiles. 2 “The United States Courts of Appeals . . . shall have exclusive jurisdic- tion to review the decisions of the Tax Court. . . .” I.R.C. § 7482(a)(1). 3 Under Chapter 1, Subchapter C of the Internal Revenue Code, the income of a “C” corporation is subject to corporate tax, and any distribu- tions that the corporation makes to its shareholders is subject to a second, individual tax. See I.R.C. § 301 et seq. 3468 BEECHER v. COMMISSIONER OF IR Both Beechers work full time for these corporations, and both corporations’ offices are located in the Beechers’ home. The corporations pay the Beechers rent for the use of this office space. In addition to renting this portion of their home, the Beechers also own five rental properties.

On their 1997, 1998, and 1999 federal…