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(2) whether respondent has satisfied his burden of proving
by clear and convincing evidence that petitioner is liable for
the civil fraud penalty under section 6663(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate the stipulated facts into our findings by this
reference. Petitioner resided in Flushing, New York, when his
petition in this case was filed.
Petitioner’s 2001 Return
During 2001, petitioner was employed by Keyspan Engineering
Associates and by Cosentini Associates.
Petitioner filed a timely Federal income tax return for 2001
on which he reported the income he had earned from his employment
during 2001. On Schedule A, Itemized Deductions, of his 2001
return, petitioner claimed itemized deductions of $31,449.06, and
on Schedule C, Profit or Loss From Business, petitioner claimed a
bad debt deduction of $20,000 and a deduction for legal expenses
of $1,300. The Schedule A itemized deductions that petitioner
claimed on his 2001 return consisted of the following:
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