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petitioner’s testimony and his denial of fraudulent intent.
Petitioner acknowledged that he continued failing to file tax
returns until the eve of trial of this case. The thrust of his
testimony is that petitioner and others pursued their course of
tax protest as long as they could get away with it. See
Niedringhaus v. Commissioner, 99 T.C. 202, 218-219 (1992).
On consideration of the facts deemed admitted and
petitioner’s testimony in opposition to the motion for summary
judgment, we conclude that there is no genuine issue as to any
material fact and that a decision may be rendered as a matter of
law.
Respondent’s motion for summary judgment, as modified in the
stipulation of settled issues, will be granted.
An appropriate order and
decision will be entered.
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