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               (2) whether respondent has satisfied his burden of proving             
          by clear and convincing evidence that petitioner is liable for              
          the civil fraud penalty under section 6663(a).                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  We           
          incorporate the stipulated facts into our findings by this                  
          reference.  Petitioner resided in Flushing, New York, when his              
          petition in this case was filed.                                            
          Petitioner’s 2001 Return                                                    
               During 2001, petitioner was employed by Keyspan Engineering            
          Associates and by Cosentini Associates.                                     
               Petitioner filed a timely Federal income tax return for 2001           
          on which he reported the income he had earned from his employment           
          during 2001.  On Schedule A, Itemized Deductions, of his 2001               
          return, petitioner claimed itemized deductions of $31,449.06, and           
          on Schedule C, Profit or Loss From Business, petitioner claimed a           
          bad debt deduction of $20,000 and a deduction for legal expenses            
          of $1,300.  The Schedule A itemized deductions that petitioner              
          claimed on his 2001 return consisted of the following:                      














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