Affirmed by published opinion. Chief Judge ERVIN wrote the opinion, in which Judge WILKINSON and Judge WILKINS joined.
OPINION
ERVIN, Chief Judge:
This is an appeal from a decision of the tax court holding petitioner, Paul Thomas, civilly liable for deficiencies in income tax payments for the years 1983, 1984, and 1985, as well as for additions to the tax as a consequence of Thomas' civil fraud. While...
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