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1. Whether respondent correctly determined that petitioner
received unreported income from bribes in the years 1981 and 1982
in the amounts of $50,000 and $206,087, respectively. We hold
that respondent's determinations are correct.
2. Whether respondent correctly determined that the entire
amount of the deficiency for 1982 was attributable to fraud for
purposes of section 6653(b)(2). We hold that she did.
Unless otherwise stated, section references are to the
Internal Revenue Code applicable to the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact and the exhibits submitted therewith are
incorporated herein by this reference. Petitioner resided in
Taos Ski Valley, New Mexico, when he filed his petition.
From 1980 through 1982, petitioner was a loan officer in the
real estate and construction lending department of the Bank of
New York (the Bank). He initially served as assistant treasurer,
and in late 1981, he was promoted to assistant vice president of
the Bank.
1(...continued)
petitioner cannot deny that a part of the underpayment was due to
fraud for purposes of sec. 6653(b) and sec. 6653(b)(1) for 1981
and 1982, respectively, it is left to decide the amount of the
addition to tax under sec. 6653(b)(2) for 1982.
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