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WAGNER v. COMMISSIONER

Docket No. 7602-88.

72 T.C.M. 309 (1996)

T.C. Memo. 1996-355

Edward A. Wagner and Barbara Wagner v. Commissioner.

United States Tax Court.

Filed August 5, 1996.

Attorney(s) appearing for the Case

Jared J. Scharf, for the petitioners. Michael D. Wilder, for the respondent.

MEMORANDUM OPINION

BEGHE, Judge:

This case is before us on respondent's motion for summary judgment under Rule 121(b)1 that petitioner Edward A. Wagner (petitioner) is liable for the fraud addition to tax for the year in issue. After concessions, the sole issue for decision is whether we should conclude, as a matter of law, that petitioner is liable for the section 6653(b) addition...

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