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proving for 1983, 1984, 1985, and 1986 that these remaining
adjustments are attributable to fraud.
Fraud- and Non-Fraud-Related Adjustments Relating to YOC
With regard to YOC, with the exception of the travel and
entertainment expenses, we believe and we so hold, that for 1983,
1984, and 1985 all of the adjustments relating to YOC that we
have sustained relating to the claimed business expenses of YOC
are attributable to fraud.
Respondent, however, has not met her burden of proving that
the erroneously claimed travel and entertainment expenses are
attributable to fraud.
The schedule set forth as an appendix to this opinion
provides separately for Elvin and for YOC a summary of the
adjustments we have sustained, the year and amount of the
adjustments, and a summary of which adjustments we conclude are
and are not attributable to fraud.
Substantial Understatement Addition to Tax
Respondent also determined that Elvin (for 1983, 1984, 1985,
and 1986) and YOC (for 1983, 1984, and 1985) are liable under
section 6661 for an addition to tax equal to 25 percent of the
respective underpayments of tax. For a taxpayer to be liable for
the substantial understatement addition to tax under section
6661, the amount of the understatement must exceed the greater of
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