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forth in respondent's requests for admission, respondent has
established by clear and convincing evidence that petitioner's
failure to file Federal income tax returns for the years in issue
was fraudulent. Thus, we shall grant respondent's Motion for
Summary Judgment and sustain the additions to tax for fraud
asserted in respondent's Amended Answer to Amended Petition for
the taxable years 1990, 1991, and 1992. Because we are granting
respondent's Motion for Summary Judgment for the additions to tax
for fraud, we do not need to consider respondent's alternate
position that petitioner is liable for additions to tax under
section 6651(a)(1).
To reflect the foregoing,
An order granting respondent's
Motion for Summary Judgment will be
issued, and decision will be
entered for respondent.
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Last modified: May 25, 2011