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POPKIN v. COMMISSIONER

Docket No. 876-83.

56 T.C.M. 294 (1988)

T.C. Memo. 1988-459

Marvin L. Popkin v. Commissioner.

United States Tax Court.

Filed September 22, 1988.

Attorney(s) appearing for the Case

Samuel S. Forman, for the petitioner. Bonnie L. Rosner, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, in a notice of deficiency dated October 13, 1982, determined a deficiency in petitioner's income tax of $201,784 and an addition under section 6653(b)1 of $100,892 for taxable year 1978. Because petitioner has conceded the amount of the income tax deficiency, the only issue left for consideration is whether petitioner is liable for the fraud addition under section...

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