MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge.
The issue for decision is whether petitioner is liable for deficiencies, additions to tax for fraud, and a fraud penalty.
FINDINGS OF FACT
Petitioner filed his 1986 and 1987 income tax returns on March 10, 1989, 1988 return on October 20, 1989, and 1989 return sometime after August 15, 1990. On September 30, 1997, respondent determined deficiencies relating to 1986 through 1989; additions...
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