- 7 -
and interposed for an improper purpose), and may invite
sanctions.
We thus hold that petitioner is estopped from denying, for
purposes of this case, that he filed a false and fraudulent
Federal income tax return, with the intent to evade income tax
for 1987.
Finally, because petitioner's fraudulent intent, for
purposes of the additions to tax under sections 6653(b)(1)(A) and
(B) has been established for 1987, it follows that the assessment
and collection of the deficiency in income tax and the additions
to tax are not barred by the expiration of the statutory
limitation period. Sec. 6501(c)(1).
Respondent's motion for partial summary judgment will be
granted.
To reflect the foregoing,
An appropriate order
will be issued.
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