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Based on our examination of the entire record in this case,
we find that respondent has established by clear and convincing
evidence that petitioner intended to evade tax for each of the
years 1992 through 1995, which he believed to be owing, by
conduct intended to conceal, mislead, or otherwise prevent the
collection of such tax. We further find on that record that
petitioner is liable for the addition to tax under section
6651(f) for each of those years.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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