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the years in issue was due to fraud. The statute of limitations,
therefore, does not bar assessment of the deficiencies or the
additions to tax for fraud for the years in issue.
Petitioners have presented no evidence or argument regarding
the additions to tax under section 6661(a) for 1984 and 1986.
The exceptions under section 6661(a)(2)(B) regarding substantial
authority for the tax treatment and adequate disclosure in the
return do not apply in this instance. Therefore, respondent's
determination will be sustained.
To reflect the foregoing and concessions of the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011