Eric Wynn - Page 3

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          and (6) in the alternative to the fraud additions for 1984,                 
          whether petitioner is also liable for an addition to tax for late           
          filing under section 6651(a).                                               
               We hold that:  (1) For 1983, petitioner is collaterally                
          estopped from denying that he committed fraud and is liable for             
          the section 6653(b)(1) fraud addition because of his guilty plea            
          to criminal tax fraud, but that petitioner is not liable for the            
          section 6653(b)(2) fraud addition, except with respect to two               
          items as to which he both pleaded guilty to criminal tax fraud              
          and has otherwise conceded; (2) for 1984, petitioner is not                 
          liable for any section 6653(b)(1) or (2) fraud additions; (3)               
          respondent's deficiency determinations are upheld for both 1983             
          and 1984; (4) petitioner is liable for additions to tax for                 
          negligence for 1984; (5) petitioner is liable for additions to              
          tax for substantial understatement for 1983 and 1984; and (6)               
          petitioner is liable for an addition to tax for late filing for             
          1984.                                                                       


                                  FINDINGS OF FACT                                    
               The parties have stipulated some of the facts, and the                 
          stipulations of fact and attached exhibits are incorporated in              
          this opinion.  Petitioner resided in Bradford, Pennsylvania, when           
          he filed his petition.                                                      
               During the years in issue petitioner was the president of              
          Renaissance Enterprises, Inc. (Renaissance).  Renaissance was               




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