MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Chief Judge:
Respondent determined deficiencies in and an addition to tax for fraud and fraud penalties in respect of petitioner's tax liabilities for 1988, 1989, 1990, and 1991. Because petitioner failed to maintain adequate tax records during the years in issue, respondent relied upon the net worth (plus expenditures) method to reconstruct petitioner's taxable income. Unless otherwise indicated, section references...
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