- 11 - forth in respondent's requests for admission, respondent has established by clear and convincing evidence that petitioner's failure to file Federal income tax returns for the years in issue was fraudulent. Thus, we shall grant respondent's Motion for Summary Judgment and sustain the additions to tax for fraud asserted in respondent's Amended Answer to Amended Petition for the taxable years 1990, 1991, and 1992. Because we are granting respondent's Motion for Summary Judgment for the additions to tax for fraud, we do not need to consider respondent's alternate position that petitioner is liable for additions to tax under section 6651(a)(1). To reflect the foregoing, An order granting respondent's Motion for Summary Judgment will be issued, and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011