OPINION
PER CURIAM:
The taxpayer is a dentist. In 1969 he was convicted after having pleaded guilty to wilfully and knowingly attempting to evade federal income taxes for the year 1964. Additionally, the Commissioner of Internal Revenue determined that the taxpayer's income tax returns for 1962, 1963, 1964, and 1965 were fraudulent under the civil fraud provisions of 26 U.S.C. § 6653. The taxpayer perfected an appeal to the Tax Court of the United States...
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