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this contention. Petitioner has not attempted to controvert the
admissions he made, under penalties of perjury, on each
application that he filed shortly after the end of each year in
issue. Indeed, these contemporaneous applications seem more
reliable than petitioner’s Federal income tax returns (which were
filed years after the fact), especially given that petitioner has
admitted that he kept no books or records and has stipulated that
he does not know how he arrived at the gross receipts reported on
his tax returns. Therefore, we sustain respondent’s
determination of the amount of petitioner’s unreported income.
Wage Expense Deductions
Petitioner offered no evidence to substantiate the wage
expense deductions he claimed on his Federal income tax returns.
Accordingly, petitioner has not established that he is entitled
to wage expense deductions greater than those allowed by
respondent.4
Additions to Tax Pursuant to Section 6651(f)
Respondent has determined that petitioner is liable for
section 6651(f) additions to tax for fraudulently failing to file
his tax returns for each of the subject years. Respondent must
establish by clear and convincing evidence that petitioner’s
4 For 1992, respondent determined that petitioner is
entitled to wage expense deductions greater than petitioner
claimed on his 1992 Federal income tax return. This
determination is not in issue.
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