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petitioner’s 1990 return fraudulently understated petitioner’s
income by $125,000.9
Based upon our examination of the entire record before us,
we find that respondent has established by clear and convincing
evidence that petitioner through Mr. Duncan intended to evade tax
for petitioner’s taxable years 1990 and 1991, which petitioner
through Mr. Duncan believed to be owing, by conduct intended to
conceal, mislead, or otherwise prevent the collection of such
tax.
We have considered all of petitioner’s contentions, argu-
ments, and requests that are not discussed herein, and we find
them to be without merit and/or irrelevant.
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An order granting respondent’s
motion will be issued, and decision
will be entered under Rule 155.
9We note that on Mar. 24, 1993, Mr. Duncan acknowledged to
respondent’s revenue agents that petitioner would have to pay
fraud penalties for its taxable years 1990 and 1991.
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