KEITH, Circuit Judge.
This is an appeal from a judgment of the Tax Court which determined that the taxpayer, James W. Sisk, was deficient in the payment of federal income taxes for the years 1979-80 in the amount of $59,674. The Tax Court imposed a fifty percent civil fraud penalty of $29,837 against the taxpayer pursuant to 26 U.S.C. § 6653(b). The Tax Court also found taxpayer liable under 26 U.S.C. § 6654 in the amount of $3,158 due to underpayment of...
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