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defaulted. See, e.g., Smith v. Commissioner, 91 T.C. 1049, 1052
(1988), affd. 926 F.2d 1470 (6th Cir. 1991).
Respondent also determined that petitioner is liable for an
addition to tax for fraud for the year in issue. When a taxpayer
fails to appear and prosecute his case, entry of a default
decision “is appropriate upon a determination in our `sound
judicial discretion’ that the pleadings set forth sufficient
facts” to support a finding that the taxpayer fraudulently
underpaid his taxes. Smith v. Commissioner, supra at 1058-1059;
see also Bosurgi v. Commissioner, 87 T.C. 1403, 1408 (1986);
Berkshire v. Commissioner, T.C. Memo. 1997-258.
Petitioner is deemed to have admitted facts sufficient to
establish his underpayment of Federal income tax for 1994. See
respondent’s answer, subparagraphs 7 o) through 7 ac), supra pp.
4-6, establishing that petitioner had unreported taxable income
of $61,750, and subparagraph 7 ad), supra p. 7, establishing
that, as a result of the foregoing, petitioner had a deficiency
in Federal income tax of $24,002 for the taxable year 1994.
Moreover, petitioner is deemed to have admitted that his failure
to file a Federal income tax return, reporting his taxable income
for 1994, was with the fraudulent intent to evade payment of his
Federal income tax for 1994. See the well-pleaded facts
concerning petitioner’s efforts to conceal and evade his tax
liability alleged in respondent’s answer, subparagraphs 7 a)
through t), and 7 ab) through an), supra pp. 3-5, 6-7,
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