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income, giving implausible explanations, and pleading guilty to
willful failure to file an income tax return under section 7203.
Considering all of the facts and circumstances of this case,
we find that respondent has proven by clear and convincing
evidence that petitioner’s failure to file an income tax return
for 1995 was fraudulent. Accordingly, petitioner is liable for
the section 6651(f) addition to tax for 1995.
Because of our holding regarding the addition to tax under
section 6651(f) for fraudulent failure to file, we need not
address whether petitioner is liable for the addition to tax
under section 6651(a)(1) for failure to file timely.
We have considered petitioner’s other arguments and find
them to be irrelevant, moot, or meritless.
To reflect the concessions of the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011