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The sole issue remaining for decision is whether petitioner
is liable for the addition to tax under section 6651(a)(1) for
each of the years at issue. We hold that he is.
FINDINGS OF FACT
Some of the facts were established for purposes of this case
pursuant to this Court's Order under Rule 91(f) dated September
18, 1996.2
Petitioner, who at all relevant times was a cardiologist
employed by Howard University and Howard University Hospital in
Washington, D.C., resided in Washington, D.C., at the time the
petition was filed.
Sometime during the spring of 1992, petitioner met Richard
Paul Todar (Mr. Todar), a certified public accountant, and asked
him to prepare his U.S. individual income tax return (return) for
1991. At the time they met, petitioner and Mr. Todar both had a
financial interest in a small emergency health clinic (clinic)
located in Houston, Texas. With the assistance of Mr. Todar,
petitioner requested and was granted an extension of time until
August 15, 1992, within which to file his 1991 return.
Sometime after April 15, 1992, petitioner provided some
records to Mr. Todar with respect to Mr. Todar's preparation of
2 Facts virtually identical to those deemed established under
Rule 91(f) were set forth in a request for admissions filed by
respondent on July 9, 1996. Each matter set forth in that
request is deemed admitted because petitioner did not file a
response thereto. See Rule 90(c).
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