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1985 taxable years,6 (2) section 6653(b)(1)(A) for petitioners'
1986 taxable years and the Lees' 1987 taxable year,7 and
6 Sec. 325(a) of the Tax Equity and Fiscal Responsibility
Act of 1982, Pub. L. 97-248, 96 Stat. 616-617, amended sec.
6653(b) effective for taxes the last day prescribed by law for
the payment of which, without regard to extensions, was after
Sept. 3, 1982. Following its amendment, sec. 6653(b) provides in
relevant part:
(1) In General.--If any part of any underpayment * * *
of tax required to be shown on a return is due to fraud,
there shall be added to the tax an amount equal to 50
percent of the underpayment.
(2) Additional Amount for Portion Attributable to
Fraud.--There shall be added to the tax (in addition to the
amount determined under paragraph (1)) an amount equal to
50 percent of the interest payable under section 6601--
(A) with respect to the portion of the
underpayment described in paragraph (1) which is
attributable to fraud, and
(B) for the period beginning on the last day
prescribed by law for payment of such underpayment
(determined without regard to any extension) and ending
on the date of the assessment of the tax (or, if
earlier, the date of the payment of the tax).
7 Sec. 1503(a) of the Tax Reform Act of 1986, Pub. L. 99-
514, 100 Stat. 2085, 2742-2743, amended sec. 6653(b) effective
for returns the due date of which, without regard to extensions,
was after Dec. 31, 1986. Following its amendment, sec. 6653(b)
provides in relevant part:
(1) In general.--If any part of any underpayment * * *
of tax required to be shown on a return is due to fraud,
there shall be added to the tax an amount equal to the sum
of--
(continued...)
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