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failed to appear at the calendar call on December 4, 1995, and no
one appeared on his behalf. We decide this motion on the basis
of the parties' pleadings, admissions, written submissions, and
other acceptable materials. For reasons stated below, we grant
respondent's motion.
Background
Petitioner lived in Florida when he filed the petition in
this case.
By notice of deficiency dated November 1, 1994, respondent
determined that petitioner has a deficiency in Federal income tax
and an addition to tax and penalties as follows:
Addition To Tax and Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6662 Sec. 6663
1989 $29,659 $6,589 $268 $21,240
Respondent determined that all but $1,339 of the deficiency
was attributable to fraud. Respondent also determined that
petitioner was liable for a penalty for negligence under section
6662 for this $1,339 part of the deficiency.
On February 27, 1995, respondent filed an answer to
petitioner's amended petition. In it, respondent alleged:
6. FURTHER ANSWERING the amended petition and in
support of the determination that a part or all of the
underpayment of tax required to be shown on the
petitioner's income tax return for the taxable year
1989 is due, in whole or in part, to fraud with the
intent on the part of the petitioner to evade tax, the
respondent alleges:
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