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By notice of deficiency dated October 21, 1993, respondent
determined deficiencies in, and additions to, petitioner's
Federal income tax as follows:
Additions to Tax
Year Deficiency Sec.6653(b)(1) Sec.6653(b)(2) Sec.6661
1985 $296,275.88 $155,784.40 1 $74,056.47
Additions to Tax
Sec.6653 Sec.6653
Year Deficiency (b)(1)(A) (b)(1)(B) Sec.6661
1986 $389,855.00 $169,812.76 1 $97,463.75
Additions to Tax
Sec.6653 Sec.6653
Year Deficiency (b)(1)(A) (b)(1)(B) Sec.6654
1987 $387,838.00 $290,878.50 1 $119.43
1 50% of the interest due on the portion of the underpayment
attributable to fraud.
Petitioner petitioned the Court to redetermine respondent's
determination of deficiencies on January 3, 1994, at which time
he resided in Brooklyn, New York. Respondent's answer included
affirmative allegations that petitioner is liable for additions
to tax for fraud under section 6653(b)(1) and (2) for the 1985
taxable year and under section 6653(b)(1)(A) and (B) for the 1986
and 1987 taxable years.
Previously, petitioner was a defendant in the criminal case
of United States v. Wapnick, docketed in the U.S. District Court
for the Eastern District of New York. The indictment charged,
inter alia, that petitioner willfully attempted to evade and
defeat Federal income tax due and owing by him for the 1985,
1986, and 1987 taxable years in violation of section 7201. On
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