S. Paul and Patricia J. Dubose - Page 10

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          underpayments attributable to unreported income were due to                 
          fraud.  Petitioner has not proven that any part of any                      
          underpayment is not attributable to fraud.  To reflect the                  
          foregoing,                                                                  
                                             Respondent’s motion to dismiss           
                                        for lack of prosecution as to                 
                                        petitioner S. Paul Dubose will be             
                                        granted and decision will be                  
                                        entered for respondent and against            
                                        petitioner S. Paul Dubose, and                
                                        decision will be entered only for             
                                        the deficiencies as to petitioner             
                                        Patricia S. Dubose.                           























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