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               As discussed, supra, Vortex’s corporate tax return for the             
          year at issue was due June 15, 1994.14  Vortex concedes it did              
          not file a tax return for FYE 1993 until after it received the              
          notice of deficiency in August 1995.  Vortex maintains that its             
          failure to file its FYE 1993 return by the extended due date was            
          not due to any attempt on its part to evade its taxes but rather            
          was due to other circumstances stemming from the investigation,             
          arrest, trial, and imprisonment of Mr. Zhadanov.  Mr. Zhadanov              
          was arrested in May 1993.  Incident to the arrest, law                      
          enforcement agents searched the Vortex facility and the                     
          Zhadanovs’ apartment and seized, among other things, many of                
          Vortex’s books and records.  In January 1994, Mr. Zhadanov                  
          pleaded guilty, and from 1994 to 1999 Mr. Zhadanov was                      
          incarcerated.                                                               
               By June 15, 1994, the deadline for filing Vortex’s FYE 1993            
          return, Mr. Zhadanov had already pleaded guilty pursuant to a               
          plea agreement that required him, among other things, to file               
          accurate Federal income tax returns on behalf of Vortex and for             
          himself.  The terms of the plea agreement provided an extremely             
          strong incentive to file accurate tax returns because the failure           
               14Corporate fiscal year income tax returns are required to             
          be filed on the fifteenth day of the third month following the              
          close of the corporation’s fiscal year.  Sec. 6072(b).  Vortex’s            
          income tax return for FYE 1993 was originally due on Dec. 15,               
          1993, but the filing deadline was extended to June 15, 1994.                
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