Now I'm confused. You say the appeals court decision was not surprising because of the original ruling. Now you say the original ruling didn't make sense.

I stand by that statement. The original ruling did not make sense. Hence, I thought it was worth the time, money and effort to appeal. At the same time, given that we are dealing with the government and the tax code, it didn't surprise me that the tax court upheld the original ruling. I sill think both the original ruling and the appeals court decision are wrong.

Ted