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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.
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