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was the subsequent $50,000 bribe promised to Suval of which
petitioner was unaware). Of that $65,000, 8 percent, or $5,000,
was paid in 1981; 46 percent, or $30,000, was paid in each of the
years 1982 and 1983. Based on that evidence, we find that of the
$7,500 that petitioner received from Suval, 8 percent, or $600,
was paid to petitioner in 1981, and 46 percent, or $3,450 was
paid to petitioner in each of the years 1982 and 1983.
Accordingly, we find petitioner to have had unreported income of
$3,450 in each of the years 1982 and 1983. See Cohan v.
Commissioner, supra.
We have already determined that the entire amount of each
such underpayment is due to fraud. Therefore, the "portion of
the underpayment * * * attributable to fraud" is the portion
of the underpayment resulting from unreported income of $3,450 in
both 1982 and 1983. Accordingly, the addition to tax under
section 6653(b)(2), for each of the years 1982 and 1983, is equal
to 50 percent of the interest payable under section 6601 with
respect to the underpayment resulting from unreported income of
$3,450.
III. Statute of Limitations
Section 6501(c)(1) provides for the assessment of tax at any
time in the case of a fraudulent return. We have found that
respondent has proven fraud on the part of petitioner for each of
the years in issue and, accordingly, the period for assessment
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