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tax during the relevant years, that we have the authority to
conduct this proceeding, and that we sustain respondent's
determinations for which petitioner has the burden of proof.
Accord Minguske v. Commissioner, T.C. Memo. 1997-573.
With respect to the additions to tax for fraudulent failure
to file, respondent argues that petitioner is liable for these
additions because: (1) He failed to file his required tax
returns, (2) he refused to cooperate with respondent's agents
during the administrative and judicial proceedings, (3) he
refused to disclose his books and records needed to calculate his
income tax liability, (4) he refused to file returns after
respondent advised him of his duty to do so, (5) he submitted
numerous letters, motions, and pleadings attempting to raise a
litany of shop-worn tax protester arguments, and (6) he took
affirmative steps to conceal his income-producing activities by
moving frivolously to quash the summons served on the Credit
Union for financial information on him.
For returns the due date for which is after December 31,
1989, determined without regard to extensions, section 6651(f)
imposes a 75-percent addition to tax where a failure to file a
return is fraudulent. See also Clayton v. Commissioner, 102 T.C.
632, 653 (1994) (inquiry into fraud under section 6651(f) is
similar to inquiry into fraud under former section 6653(b)(1)).
Fraud is the intentional wrongdoing on the part of a taxpayer to
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