OPINION
CLAPP, Judge:
This matter is before us on respondent's motion for leave to file an amended answer. Pursuant to an order, an evidentiary hearing was held in Pasadena, California, on September 17, 1987.
Factual Background
The years in issue in the underlying case are 1959, 1963-1966, and 1968. Petitioner failed to file tax returns for any of these years. Beginning in 1970, a...
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