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the time the return for each of the other years was due. During
the years at issue, petitioner expended funds, inter alia, on
several skiing vacations, expensive clothing, weekly visits to
the hairdresser, and some very fine antiques that she used as
office furniture.
The income, expenses, and tax shown in the copy of peti-
tioner's return for each of the years at issue that Mr. Golemb
presented to the revenue agent on May 21, 1992, have been ac-
cepted by the Service, with minor adjustments, as correct.
Taking those minor adjustments into account, petitioner realized
adjusted gross income of $23,114, $43,934, $31,854, $46,005,
$47,605, and $110,057 for 1985 through 1990, respectively. As a
result, petitioner is liable for, and has signed an agreement
with respect to the years at issue (1985-1990 Form 870) in which
she agreed that she is liable for, additional taxes for those
years of $7,103, $15,975, $12,291, $16,569, $17,310, and $39,239,
respectively. In addition, petitioner is liable for, and agreed
in the 1985-1990 Form 870 that she is liable for, the additions
to tax under section 6654 for failure to pay estimated taxes in
the amounts of $407, $773, $663, $1,059, $1,173, and $2,583 for
1985 through 1990, respectively.
On April 18, 1997, respondent issued a notice of deficiency
(notice) to petitioner for 1985 through 1987. Respondent de-
termined in that notice that petitioner is liable for the ad-
ditions to tax for fraud under section 6653(b)(1) and (2) for
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