MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
This case is before us on petitioner's motion for partial summary judgment. The case involves tax years 1984, 1985, and 1986. One of the issues is whether petitioner is liable for the addition to tax for fraud for each of those years. The parties agree that, absent fraud, the period of limitations for 1984 has expired. The parties also agree that petitioner's Federal income tax returns for the taxable...
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