Opinion by Judge COYLE; Partial Concurrence and Partial Dissent by Judge REINHARDT.
COYLE, District Judge:
Taxpayer William Little appeals from the Tax Court's decision imposing additions to tax for negligence, pursuant to 26 U.S.C. § 6653(a), and additions to tax for substantial understatement of tax, pursuant to 26 U.S.C. § 6661, for the tax years 1984, 1985, and 1986. The Commissioner determined that Taxpayer was not entitled to capital gain treatment...
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