The following excerpt is from U.S. v. DiMeo, 65 F.3d 176 (9th Cir. 1995):
We review for clear error the district court's finding of fact that a taxpayer executed a waiver of the statute of limitations on assessment. See United States v. Conry, 631 F.2d 599, 600 (9th Cir.1980).
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