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          respondent’s determinations with respect to the unreported income           
          received by petitioner with respect to Pieces of Eight.  We                 
          accordingly sustain respondent’s determinations of petitioner’s             
          liability for self-employment tax.                                          
          Sections 6653(b) and 6651(f) Additions to Tax                               
               Respondent determined that petitioner is liable for the                
          addition to tax for fraud provided by section 6653(b)(1)(A) and             
          (B) for 1987 and section 6653(b)(1) for 1988.  Respondent also              
          determined that petitioner is liable for the addition to tax for            
          fraudulent failure to file a return provided by section 6651(f)             
          for 1989.8  In deciding whether a failure to file is fraudulent,            
          we consider the same elements as are considered in imposing the             
          addition to tax for fraud provided by former section 6653(b) and            
          present section 6663.  Clayton v. Commissioner, 102 T.C. at 653.            
          Accordingly, we have consolidated our discussion of respondent’s            
          fraud determinations.                                                       
          8                                                                           
               Sec. 6664(b) provides that, for tax returns the due date for           
          which (determined without regard to extensions) is after Dec. 31,           
          1989, neither the negligence penalty provided by sec. 6662 nor              
          the fraud penalty provided by sec. 6663(a) applies where a tax              
          return has not been filed.  Clayton v. Commissioner, 102 T.C.               
          632, 652 (1994).  Sec. 6651(f), however, provides that, where a             
          failure to file a return is fraudulent, the addition to tax                 
          imposed by section 6651(a) is increased to 15 percent of the                
          amount required to be shown as tax for each month the failure               
          continues, up to a maximum of 75 percent of the amount.                     
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