Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
In a timely statutory notice of deficiency, respondent determined a deficiency in petitioner's Federal income tax for taxable year 1981 of $59,333. Additionally, he determined that the underpayment of tax was due to fraud and determined an addition to tax of $29,667 (50 percent of the underpayment).
After concessions, the issues for our consideration are: (1) Whether petitioner's December...
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