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The deemed admissions establish that there is no genuine issue of
material fact with respect to the underlying deficiencies and
support respondent's determination in this regard. Marshall v.
Commissioner, supra at 271-272; Freedson v. Commissioner, supra
at 334-336. We sustain respondent's determination of the
deficiencies for 1987 through 1989 as shown in the notice of
deficiency.
B. Additions to Tax for Fraud
The second issue is whether petitioner is liable for the
additions to tax for fraud under section 6653(b)(1)(A) and (B)
for 1987, section 6653(b)(1) for 1988, and section 6651(f) for
1989. For 1987, section 6653(b)(1)(A) imposes an addition to tax
equal to 75 percent of the portion of the underpayment
attributable to fraud, and section 6653(b)(1)(B) imposes an
addition to tax equal to 50 percent of the interest payable under
section 6601 with respect to that portion. For 1988, section
6653(b)(1) imposes an addition to tax equal to 75 percent of the
portion of an underpayment that is due to fraud. For 1989,
section 6651(f) imposes an addition to tax of similar proportion
where a failure to file a return is fraudulent. Because these
provisions are analyzed similarly as to the determination of
fraudulent intent, we consolidate our discussion of fraud
determinations. Clayton v. Commissioner, 102 T.C. 632, 653
(1994).
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