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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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