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We must decide:
1. Whether petitioners received commission income of
$487,104 and $182,020 in 1980 and 1981, respectively.2 We hold
they did.
2. Whether petitioners received dividend income of $22,135
and $19,510 in 1980 and 1981, respectively. We hold they did.
3. Whether petitioners received interest income of $7,791,
$37,612, and $8,429 in 1980, 1981, and 1982, respectively. We
hold they did.
4. Whether Mr. Fields (petitioner) is liable for additions
to his 1980 through 1982 taxes for fraud. We hold he is.
5. Whether the 3-year period of limitation under section
6501(a) bars the assessment and collection of tax for any of the
subject years. We hold it does not.
6. Whether Mrs. Fields is an innocent spouse under section
6013(e). We hold she is not.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the subject years. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
2 The notice of deficiency states that petitioners received
commission income of $825,025 and $307,005 in 1980 and 1981,
respectively. Respondent has conceded that $337,921 and $124,985
of this income for the respective years was attributable to (and
includable in the gross income of) petitioner's business partner,
Dr. Walter F. Young.
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