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2001; and (3) whether petitioner is liable for penalties pursuant
to section 6662(a) for 1999, 2000, and 2001.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulation of facts,
and the attached exhibits are incorporated herein by this
reference. At the time he filed the petition, Francis M.
Gagliardi (Mr. Gagliardi) resided in El Cajon, California.
Mr. Gagliardi’s Life Before 1991
Mr. Gagliardi did not graduate from high school. The last
year Mr. Gagliardi attended high school was 1979.
After high school, Mr. Gagliardi was employed as a machine
operator by Buck Knives. Following his work at Buck Knives, from
approximately 1984 to 1987 Mr. Gagliardi worked as a truck driver
for his brother Dan Gagliardi.
In 1989, Mr. Gagliardi purchased an 18-wheel truck and
thereafter ran his own trucking business, called American
Redball, as a sole proprietorship. Mr. Gagliardi’s duties for
American Redball included running the business and driving the
truck. Mr. Gagliardi hauled materials for military defense shows
and trade shows.
While operating American Redball, Mr. Gagliardi did not keep
a log of his income and expenses; instead he kept his receipts
for the preparation of his income tax returns. Mr. Gagliardi
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