Jeff R. Taylor - Page 7

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          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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