Edward J. Frami - Page 6

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          amounts for 1993 and 1994 were insufficient to generate a Federal           
          income tax liability.  Petitioner also explained that he had                
          records that would substantiate that he would not be liable for             
          Federal income tax, but that he refused to show them to                     
          respondent or the Court because of his disagreement with the                
          system and also because he invoked his privilege against self-              
          incrimination under the Fifth Amendment of the U.S. Constitution            
          either with respect to presenting records or filing a complete or           
          detailed return.  In that regard, petitioner indicated that he              
          did not knowingly commit any crime and that he did not believe              
          that his records would show that a crime had been committed.                
          Petitioner's concern focused on the possibility that the                    
          documents could be used as the basis for developing a criminal              
          case.                                                                       
               Petitioner's testimony also provided the basis for finding             
          that his actual cost of living for 1993 and 1994 was below                  
          average and would not have been commensurate with BLS averages              
          that respondent utilized for the reconstruction of the 1993 and             
          1994 income.  At the conclusion of petitioner's brief statement             
          and testimony, respondent's counsel conducted a thorough cross-             
          examination of petitioner concerning the matters stated on                  
          direct.  Petitioner was candid, and he was not evasive.  After              
          offering no documents at all and no testimony other than his own,           
          petitioner rested.                                                          





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