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other court, and this opinion shall not be treated as precedent
for any other case.
Petitioner fraudulently underpaid his Federal income taxes
for 1992, 1993, and 1994 and subsequently agreed to the
assessment of deficiencies for those years. Respondent then
determined civil fraud penalties under section 6663. Despite
petitioner’s stipulation, as well as the record’s independent
demonstration that he filed fraudulent returns with intent to
evade tax, petitioner contends that imposition of civil fraud
penalties would be unfair. Thus, the issue for decision is
whether respondent’s penalty determination should be sustained.
We hold that it should.
Background
Most of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ extensive
stipulation of facts and accompanying exhibits.
At the time that the petition was filed, Donald Ray Hartley
resided in Jacksonville, Florida.
In early 1995, petitioner told his brother-in-law that he
needed someone to help him file several years’ worth of
delinquent Federal income tax returns. Petitioner had not yet
filed for those years because he knew he would owe money.
Petitioner’s brother-in-law introduced him to a man named
Robert Rudolph (Mr. Rudolph), who was then employed by the
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