The following excerpt is from Soborski v. C.I.R., 967 F.2d 591 (9th Cir. 1991):
The tax court's determination of unreported income is a finding of fact and will not be overturned unless it is clearly erroneous. See Keogh v. Commissioner, 713 F.2d 496, 501 (9th Cir.1983).
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