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" ... Also, just last year the Eighth Circuit ruled in the case of Muncy that Muncy was entitled to the d.o. The court reversed the Tax Court which held that the issue is frivolous; and, the Eighth Circuit remanded the case, ordering IRS to produce the d.o. So this decision in effect holds that the Nestor dissentors and three Eighth CircuitĀ judges acted with frivolity in reaching the decisions they reached. ... "