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is not liable for the fraud additions, petitioners are jointly
and severally liable for additions to tax for failure to file and
negligence.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
by this reference. Petitioners were residents of Bellmore, New
York, when they filed their petition.
1. Mark's Education, Work Experience, and Drug Use
Petitioners were married in 1969, the year Mark began law
school, and have two children. In 1972, Mark graduated from St.
John's University-School of Law, ranked ninth in a class of 218.
Mark took and passed two tax courses: Federal income tax, and
estate and gift tax. In 1972-73, he attended Harvard Law School
in a Master of Laws degree program, but failed to complete the
program. Mark did not complete a required term paper because of
an episode of drug abuse. Although he passed the New York State
bar exam, Mark never became a member of the bar.
In 1973, Mark went to work for Goldman, Sachs & Co., and
remained employed there until he resigned in 1983. In 1979, Mark
became a vice president in the security sales division, where he
worked as a restricted stock specialist, brokering deals for
wealthy clients to sell large blocks of corporate shares that
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