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9th Cir Abarta addition to tax affd affg AFTR 2d agents agreement amended amount Amworth assets burden of proof cash Cite claimed Commis Commissioner corporation December 31 deduction deposits depreciation Docket entitled evidence exempt FACT AND OPINION Federal income tax FINDINGS OF FACT fraud gross income Helvering Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service lease loan loss mailed Memorandum Decisions MEMORANDUM FINDINGS Memorandum Opinion ment notice of deficiency º º ºil ºld P-H Fed P-H Memo TC paid parties partnership payments peti petition petitioner petitioner's profit purchase pursuant receipts received record residence Respondent determined respondent's Rules of Practice stipulated supra T.C. Memo Tax Court Rules tax return tax under section taxpayer TC Memo tion tioner transfer underpayment United