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SHAPOURI v. COMMISSIONER

Docket No. 35202-86.

57 T.C.M. 1555 (1989)

T.C. Memo. 1989-474

Mahmoud J. Shapouri, AKA Joe Shapouri, AKA Joseph Shapouri v. Commissioner.

United States Tax Court.

Filed August 31, 1989.

Attorney(s) appearing for the Case

Gilbert T. Gembacz, for the respondent.

Memorandum Opinion

RUWE, Judge:

This matter is before the Court on respondent's motion under Rule 123(b)1 to dismiss for lack of prosecution as to the tax deficiency and additions to tax under sections 66542 and 6661. Respondent has also requested the Court to find petitioner liable for the additions to tax for fraud under section 6653(b)(1) and (2). As to the fraud issue, respondent bears the burden...

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