T.C. Memo. 1998-226
UNITED STATES TAX COURT
RICHARD A. FREY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23834-96. Filed June 29, 1998.
W. Waverly Townes, for petitioner.
Andrew M. Winkler, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Respondent determined deficiencies in
petitioner's Federal income tax and penalties for fraud as
follows:
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