PER CURIAM:
In this civil tax case, the appellant, Philip J. Mandina, challenges the Tax Court's determination of a $178,902.00 deficiency in Mandina's 1969 federal income tax return and its assessment of an $89,451.00 fraud penalty relating to that return.
FACTS
The Tax Court determined the deficiency in Mandina's return by tracing to him unreported...
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