David M. Leggett - Page 19




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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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