MEMORANDUM OPINION
THORNTON, Judge:
This proceeding is before us on respondent's motion for summary judgment. The issues for decision are whether petitioner underreported his 1996 gross income by $1,551,863 and whether petitioner is liable for the section 6663 fraud penalty.
When he petitioned the Court, petitioner resided in Thousand Oaks, California.
Background
Petitioner is an attorney. During 2002, the U.S. Attorney filed...
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