Jerry V. Rice - Page 8




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               Respondent has proven by clear and convincing evidence that            
          petitioner fraudulently underpaid tax for 1989.  Accordingly, the           
          fraud penalty is justified in this case, and petitioner has not             
          proven that any part of the underpayment is not attributable to             
          fraud.                                                                      
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          

































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