ROSENTHAL v. COMMISSIONER

Memorandum Findings of Fact and Opinion

PARR, Judge:

This case is before us on respondent's Motions for Default as to deficiencies and for Summary Judgment as to fraud. We treat both as motions for summary judgment. In his notice of deficiency respondent determined deficiencies and additions to tax in the following amounts for the following years:

                                 Addition to Tax
Year          Deficiency...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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