MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
The issue for decision is whether petitioner is liable for fraud penalties relating to 1991, 1992, and 1993.
FINDINGS OF FACT
In 1974, petitioner began operating Southeast Trust Investment Management (Southeast Trust), a sole proprietorship registered as an investment adviser with the Securities and Exchange Commission. In the mid-1970s, Southeast Trust's name was changed to Trust Investment...
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