GARTH, Circuit Judge:
The United States Tax Court disallowed certain deductions taken by the taxpayer, John C. Coggin, III, on his 1980, 1981 and 1982 federal income tax returns. The Tax Court assessed deficiencies in the amount of $128,941.30; and additions to tax, pursuant to I.R.C. §§ 6653 (Additions to Tax for Negligence and Fraud) & 6661 (Additions to Tax for Substantial Understatement of Liability), in the amount of $15,144.05, plus 50% of the...
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