Affirmed by published opinion. Judge DIANA GRIBBON MOTZ wrote the opinion, in which Judge WIDENER and Judge TRAXLER joined.
OPINION
DIANA GRIBBON MOTZ, Circuit Judge:
Robert D. Grossman, Jr., appeals the tax court's finding that he committed civil tax fraud in connection with his 1985 and 1986 income tax returns. Grossman contends that the Commissioner failed to produce sufficient evidence to prove tax fraud,
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