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(l) Petitioner failed to report income from the
operation of the business, Re-Entries Consignment Shop
in the amount of $3,003 for 1989, all with the
fraudulent intent to evade tax for the period.
(m) Petitioner filed his 1989 return on September
18, 1990, with the knowledge that he clearly failed to
report all income received for the year, whether
illegal or legal, all with the fraudulent intent to
evade tax for the year.
(n) Petitioner failed to report taxable income of
$94,469 for taxable year 1989, all with the fraudulent
intent to evade tax for the year.
(o) Petitioner failed to report his tax liability
in the amount of $29,659 for 1989, all with the
fraudulent intent to evade tax for the year.
(p) A part or all of the underpayment of tax which
petitioner was required to show on his income tax
return for the taxable year 1989 is due to fraud.
7. FURTHER ANSWERING the Amended Petition and in
the alternative to the additions to the tax for the
taxable year 1989 due from the petitioner under the
provisions of I.R.C. section 6663 and in support of
respondent's claim for additions to the tax for the
taxable year 1989 under the provisions of I.R.C.
section 6662(a) in the amount totaling $5,664, the
respondent alleges as follows:
(a) Petitioner was clearly aware that when he
filed his delinquent income tax return that he had not
reported all the income received by him for the taxable
year 1989.
(b) Petitioner's failure to file timely a return
for 1989 and report his income received during the year
and petitioner's underpayment of income tax for the
taxable year 1989 were due to negligence and the
intentional disregard of rules and regulations, as is
more fully set forth by the facts in paragraph 6 above,
which facts are incorporated herein by reference * * *.
Petitioner did not file a reply to respondent's allegations.
On May 22, 1995, respondent filed a motion under Rule 37(c) to
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