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2. Whether petitioner Leo Levitt is collaterally estopped
from contesting factual findings made by the U.S. bankruptcy
court in a trial relating to respondent's tax claims against
Resyn Corp., which he controlled. We hold that he is.
3. Whether respondent's determination was arbitrary. We
hold that it was not.
4. Whether petitioners had unreported dividend income
during the years in issue. We hold that they did.
5. Whether petitioner Leo Levitt is liable for fraud for
1963. We hold that he is not because there is no evidence of the
contents of that return.
6. Whether petitioner Leo Levitt is liable for fraud for
1964 to 1970. We hold that he is.
7. Whether the statute of limitations bars assessment of
tax for petitioners for 1964 to 1970. We hold that it does not.
8. Whether petitioner Ruth Levitt is an innocent spouse
under section 6013(e) for any of the years in issue. We hold
that she is not.
References to petitioner are to Leo Levitt. Section
references are to the Internal Revenue Code in effect during the
years in issue. Rule references are to the Tax Court Rules of
Practice and Procedure. References to rule 6(e) are to rule 6(e)
of the Federal Rules of Criminal Procedure.
Some of the facts have been stipulated and are so found.
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