MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notices dated April 8, 2003, respondent determined deficiencies in and additions to petitioner's 1995, 1996, 1997, 1998, 1999, 2000, and 2001 Federal income taxes. The issues for decision are whether petitioner received unreported income and is liable for the sections 6654(a)
FINDINGS OF FACT
In 1980, petitioner...
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