- 2 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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