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We must also determine whether petitioner is liable for the
additions to tax.
Some of the facts have been stipulated and are so found.
The stipulation of facts, with accompanying exhibits, is
incorporated herein by this reference. We need find few facts in
addition to those stipulated and, accordingly, do not separately
set forth those findings. We include additional findings of fact
in the discussion that follows.
At the time the petition was filed, petitioner resided in
Bronx County, New York.
II. Background
In 1983, petitioner was a member of Congress, from the 19th
District in New York. Wedtech was a manufacturing company
located in New York City, which received contracts from the
U.S. Department of Defense. In 1987, petitioner was indicted on,
and in 1988 he was convicted of, various counts arising out of
his relationship with Wedtech. Among those counts were
(1) racketeering in connection with his demand and receipt of the
Wedtech shares and $50,000 in exchange for influencing public
officials to grant a lease to Wedtech; (2) extortion, bribery,
and receipt of an unlawful gratuity in connection with his demand
and receipt of the Wedtech shares; (3) making false statements in
concealing his ownership of the Wedtech shares; (4) filing false
income tax returns for failing to report income derived from
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