CANBY, Circuit Judge.
Wallace Ward appeals a decision of the Tax Court. Ward argues that the Tax Court violated the Double Jeopardy Clause by imposing an addition to tax for fraud under 26 U.S.C. § 6653(b) (1986), when he had previously been convicted of tax evasion for the same taxable years. He also challenges the Tax Court's conclusion that it lacked jurisdiction to review the IRS's jeopardy assessments against him. Finally, he asserts that the Tax Court erred...
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