Kane, J.
In 1991, the Internal Revenue Service determined that petitioner should have reported a greater taxable income on his 1982 federal income tax return and that he owed over $1,000,000 in additional taxes for that tax year. He challenged that determination in federal court. The United States Tax Court revised the deficiency and held that petitioner owed $769,096 in additional income tax, plus a penalty of $38,455. By decision entered November 9, 1995, the United...
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