Rehearing and Rehearing En Banc Denied September 30, 1983.
WESLEY E. BROWN, Senior District Judge.
This is an appeal from a decision of the United States Tax Court which sustained the Commissioner's determination of certain deficiencies in the federal tax returns of appellant, Paul F. Gray, Jr., for the years 1968, 1969, and 1970, which imposed certain fraud penalties pursuant to 26 U.S.C. § 6653(b). In particular, the Tax Court found that Gray was collaterally...
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