Donald G. Ford - Page 11

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               The facts alleged in respondent’s affirmative pleadings are            
          sufficient to establish fraud by clear and convincing evidence.             
          Petitioner received substantial amounts of unreported income.               
          Bradford v. Commissioner, 796 F.2d 303, 308 (9th Cir. 1986),                
          affg. T.C. Memo. 1984-601.  Petitioner’s pattern of substantially           
          underreporting income for several years is strong evidence of               
          fraud, Holland v. United States, 348 U.S. 121, 137-139 (1954), as           
          is the fact that he deliberately overstated his deductions,                 
          Drobny v. Commissioner, 86 T.C. 1326, 1349-1351 (1986).                     
               The facts pleaded in respondent's answer clearly establish             
          that petitioner fraudulently underpaid his income taxes for 1988            
          and 1989.  Thus, we will grant respondent's motion for default              
          pursuant to Rule 123(a).                                                    


                                                  An appropriate order and            
                                             decision will be entered.                



















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