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(5) alternatively, should petitioner not be held liable for
the additions to tax for fraud, whether he is liable for the
addition to tax for failure to file timely pursuant to section
6651(a)(1) for each of taxable years 1987, 1988, and 1989;
(6) alternatively, should petitioner not be held liable for
the additions to tax for fraud, whether he is liable for the
additions to tax for negligence pursuant to section 6653(a)(1)(A)
and (B) for taxable year 1987 and section 6653(a)(1) for taxable
year 1988;
(7) whether petitioner is liable for the addition to tax
for a substantial understatement of income tax pursuant to
section 6661(a) for taxable year 1987; and
(8) whether petitioner is liable for the addition to tax
for failure to pay estimated income tax pursuant to section
6654(a) for each of taxable years 1988 and 1989.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91. The parties' stipulations are incorporated herein by
reference and are found accordingly.2
2
In the stipulation of facts, respondent objected to certain
exhibits offered by petitioner, some of which petitioner has
cited on brief. Respondent, however, has neither addressed those
objections on brief nor advanced any argument concerning them.
We therefore consider those objections abandoned. Midkiff v.
Commissioner, 96 T.C. 724, 734 (1991), affd. sub nom. Noguchi v.
Commissioner, 992 F.2d 226 (9th Cir. 1993).
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