Memorandum Findings of Fact and Opinion
COHEN, Judge:
This case exemplifies the self-imposed predicament in which numerous taxpayers have placed themselves in recent years. Unreasonable reliance on bad advice has resulted in determination of maximum tax liability, additions to tax, and liability for substantial interest. Mr. Langseth has narrowly escaped a damage award against him for instituting a frivolous or groundless action, which, in future cases,...
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