FLAUM, Circuit Judge.
The United States Tax Court entered judgment against Herbert G. Whyte for underpaying his federal income tax for the taxable years of 1976-78. The Tax Court also upheld the imposition of fraud penalties for these years. Whyte appeals, arguing that the Tax Court erred in not permitting him to carry forward an unreported foreign expropriation loss incurred in 1975 to offset his income tax deficiencies in 1976-78. We affirm.
I.
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