Michael W. Duncan - Page 13

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          claimed a filing status of single in his respective returns for             
          those years.                                                                
               Based upon our examination of the entire record before us,             
          we find that respondent has established by clear and convincing             
          evidence that petitioner intended to evade tax for his taxable              
          years 1990 and 1991, which he 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 and decision will be entered           
                                        for respondent.                               





















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