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determined additions to tax pursuant to sections 6653(a)(1)1 and
6661 in the amounts of $38,943 and $194,717, respectively.
The issues for decision are: (1) Whether respondent
fraudulently induced petitioner to execute a Form 872 (Consent to
Extend the Time to Assess Tax) and is therefore estopped from
relying upon petitioner's consent to extend the period of
limitations; (2) whether the presumption of correctness should
attach to respondent's determination of unreported income; (3)
whether petitioner was the owner of five antique automobiles and
realized gain on their sale for a price of $3 million in 1988;
(4) if we find that petitioner owned the automobiles in issue,
whether he is entitled to bases in three of the automobiles in
excess of that determined by respondent; (5) whether petitioner
is liable for an addition to tax for negligence or intentional
disregard of rules or regulations pursuant to section 6653(a)(1);
and (6) whether petitioner is liable for an addition to tax for a
substantial understatement of income tax pursuant to section
6661.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and supplemental stipulations of facts
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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