Duncan & Associates - Page 17

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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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