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tax returns; petitioners have failed to prove the Yogurt
Station's entitlement to additional deductions for unclaimed
business expenses. Accordingly, we sustain respondent's
determination of the deficiencies for 1989, 1990, and 1991.
4. Civil Fraud Penalty
The addition to tax in the case of fraud is a civil sanction
provided primarily as a safeguard for the protection of the
revenue and to reimburse the Government for the heavy expense of
investigation and the loss resulting from a taxpayer's fraud.
Helvering v. Mitchell, 303 U.S. 391, 401 (1938). Respondent has
the burden of proving, by clear and convincing evidence, an
underpayment for each year and that some part of the underpayment
was due to fraud. Sec. 7454(a); Rule 142(b); Katz v.
Commissioner, 90 T.C. 1130, 1143 (1988); Otsuki v. Commissioner,
53 T.C. 96, 105 (1969). If respondent establishes that any
portion of the underpayment is attributable to fraud, the entire
underpayment is treated as attributable to fraud and subjected to
a 75-percent addition to tax or penalty, except with respect to
any portion of the underpayment that the taxpayer establishes is
not attributable to fraud. Sec. 6663(b).
Fraud is intentional wrongdoing on the part of the taxpayer
with the specific purpose to evade a tax believed to be owing.
McGee v. Commissioner, 61 T.C. 249, 256 (1973), affd. 519 F.2d
1121 (5th Cir. 1975). The existence of fraud is a question of
fact to be resolved from the entire record. Gajewski v.
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