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1991, 1992, and 1993 of $19,078.50, $2,162.25, $7,412.25, and
$26,907, respectively. After concessions by the parties, the
issues for decision are:
(1) Whether assessment of petitioner’s 1990, 1991, 1992,
and 1993 taxes is barred by the period of limitations in section
6501(a). Because we find that petitioner filed false and
fraudulent returns with the intent to evade tax for 1990, 1991,
1992, and 1993, we hold that assessment is not barred;
(2) whether Taxman, Inc. (Taxman), and West Fargo
Investment Corp. (WFIC) should be disregarded because they are
mere alter egos of petitioner. We hold that they should not;
(3) whether petitioner earned real estate commissions of
$56,196, $18,552, $1,566, and $139,080 in 1990, 1991, 1992, and
1993, respectively. We hold that petitioner earned a real estate
commission of $1,566 in 1992 and that petitioner did not earn
real estate commissions in 1990, 1991, or 1993;
(4) whether petitioner realized capital gain of $25,000
from the sale of Jondahl Insurance in 1990 and commissions from
the sale of crop hail insurance in 1990 and 1991 of $12,882 and
$3,142, respectively. We hold that petitioner received capital
gain of $14,962 and insurance commissions of $10,038 in 1990, and
that petitioner did not earn insurance commissions in 1991;
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