MEMORANDUM OPINION
OREN HARRIS, Senior District Judge.
This matter came on for trial pursuant to regular notice on April 24, 1984. The parties stipulated a substantial portion of the facts of the case and the Court heard the testimony of Internal Revenue Service Special Agents George Stewart and Harry Bostwick on behalf of plaintiff and of Theodore Skrivanos on his own behalf. Based upon said stipulation and testimony, together with the exhibits admitted...
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