Court of Appeals for the Sixth Circuit May 21, 2002, 00-2375 (William D. Zack v. Commissioner of Internal Revenue)

OPINION

GILMAN, Circuit Judge.

William D. Zack challenges the determination made by the Commissioner of Internal Revenue that Zack is liable (1) for income tax deficiencies for the tax years 1985 and 1986 based upon unreported income, and (2) for additions to tax for fraud and substantial understatement of tax with regard to the deficiencies for those years.