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fully disclose all of the facts to his return preparer, Meeks.
In addition, petitioner did not make adequate disclosures on his
returns. Accordingly, respondent's determination is sustained.
To reflect the foregoing,
An appropriate order will
be issued and decisions will be
entered under Rule 155.13
13 The $180,000 petitioner reported as "other consulting
fees" on his 1984 return should be subtracted from the total
amount of income we have determined that petitioner failed to
report from the partnerships and Newtowne.
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