PER CURIAM.
Section 6653(b) of the Internal Revenue Code provides that "if any part of any underpayment ... of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 50 percent of the underpayment." The issue presented in this case is whether the Commissioner may assess civil fraud penalties on a tax protester who filed numerous false W-4 forms in 1980 and 1981 and failed to file tax returns in those years. Appellant...
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