Paul A. Bilzerian - Page 17




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          tax liability for 1986.12  Under these circumstances, petitioner            
          cannot insulate himself from the negligent omission of $4 million           
          of taxable income from the return.  Accordingly, we hold that               
          petitioner is liable for the additions to tax for negligence for            
          1986.                                                                       

                                                  Decision will be entered            
                                             under Rule 155.                          



























               12The $2 million difference is attributable to the fact that           
          petitioner’s adjusted gross income and tax liability shown on the           
          original return was underreported by approximately 40 percent.              





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