J. BLAINE ANDERSON, Circuit Judge:
The Commissioner issued a 90-day letter claiming that Weimerskirch had not reported income he allegedly received from selling heroin. Weimerskirch petitioned the Tax Court for redetermination of the deficiency. 26 U.S.C. § 7442, et seq. After the Tax Court upheld the deficiency determination, Weimerskirch appealed to this court. 26 U.S.C. § 7482.
The Tax Court held that Weimerskirch had failed to rebut the...
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