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additional AFTR agreement amount assets bad debt bank basis capital gain cash cent Cite as fl claimed collector of internal Commissioner computed Conklin Pen corporation cost Court decedent decedent's December 31 deduction deficiency deposits depreciation disallowed Docket due to fraud entered under Rule estate tax evade tax evidence excess profits tax expenses FACT AND OPINION farm filed Findings of Fact follows fraud with intent gift gift tax gross income held income tax returns intent to evade interest Internal Revenue Code issue January lease Leona Lewis liability loan loss March 15 MEMORANDUM FINDINGS ment operation ordinary income Ottoway P-H Memo TC P-H TC paid parties partner partnership payments penalty peti petitioner petitioner's profits purchase receipts received record reported respondent determined respondent's Schwerin shares sold spondent Starr Pen Company stipulated taxable taxpayer testimony tion tioner transaction trust wife Zwyns