HARLINGTON WOOD, Jr., Circuit Judge.
Raymond Valenti, as he himself admits, was a good carpenter but a bad record-keeper. He kept no records of expenses, deductions or income from his carpentry business. He did not have a bank account and he dealt exclusively in cash. Beginning as early as 1970, Valenti also failed to pay his federal income taxes. After several years of assisting him in preparing late returns and negotiating settlements for unpaid taxes, the IRS lost...
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