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During the years in issue, petitioner maintained a home in
Fairfield, Connecticut, that had 16 rooms and was situated on
10.6 acres of land. Petitioner acquired a collection of
automobiles. As of 1979, petitioner maintained at his residence
in Connecticut no fewer than 10 automobiles, including a 1979
Rolls Royce, a 1977 Jaguar, two 1972 Ferraris, and 5 Mercedes
ranging from the 1971 model to a 1979 model. Petitioner
registered a 1975 Pontiac in his name, but all of the other
automobiles were registered in the name of International
Automobiles, Ltd., an entity that purported to be a business
conducted by petitioner or by petitioner and Ms. Barth as
partners, but which conducted little or no actual business
activity.
During the years in issue, petitioner submitted financial
statements to various institutions. On financial statements
dated September 29, 1977, October 10, 1978, and April 19, 1979,
petitioner represented that his compensation from his law firm
was $225,000. On two financial statements dated September 19,
1980, he represented that his compensation from the law firm was
$250,000. In March 1980, petitioner signed a Form 1120S, U.S.
Small Business Corporation Income Tax Return, for his law firm.
That return showed petitioner's compensation as $700,000.
Petitioner, however, did not file that return.
Petitioner did not file timely Federal income tax returns
for the years in issue for himself, for the law firm, or for
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