C. Richard Roose, Jr. and Betty B. Roose - Page 14

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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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