Adnan Al Kaissy - Page 26

                                               - 26 -                                                  

            standpoint, at least partially, they were paying for their                                 
            airline tickets, but there is nothing to indicate that they                                
            understood because of the nature or the manner in which payment                            
            was made for those tickets, or from the fact, if they knew, that                           
            the value of the tickets was not included on the Forms 1099                                
            furnished to them, that they were not entitled to claim a                                  
            deduction for the airline tickets.  Certainly, there is no clear                           
            and convincing evidence to the effect that petitioner did                                  
            understand this fact.  We hold that respondent has failed to show                          
            by clear and convincing evidence that any part of the                                      
            underpayment of tax for any of the years 1982, 1983, or 1984 was                           
            due to fraud with intent to evade tax.                                                     
                  Since there are years involved other than the years 1982                             
            through 1984,                                                                              

                                                            Decision will be entered                   
                                                      under Rule 155.                                  

Page:  Previous  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  

Last modified: May 25, 2011