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(2) Gleave
In part I.B. of this opinion we considered the parties’
disputes as to the amounts of Gleave’s income in order to
determine whether respondent proved by clear and convincing that
Gleave has an underpayment of tax. After examining the evidence
in the record, we concluded that respondent carried this burden
for each of the years in issue. This conclusion applies also to
our consideration of the additional addition to tax under section
6653(b)(2) for 1982.
In particular, we conclude that respondent has proven by
clear and convincing evidence that Gleave omitted from 1982
taxable income $106,038.75 (supra table 10), less the deductions
described in our Findings of Fact (supra note 8 and associated
text) and his personal exemption, and that the underpayment of
tax resulting from this omission is attributable to fraud.
We hold for respondent as to the amount of underpayment
resulting from this omission; we hold for petitioner as to any
other amount of underpayment for 1982.
II. Amounts of Deficiencies
In part I of this opinion respondent had the burden of
proving, by clear and convincing evidence, that there were under-
payments of tax, some part of which was due to fraud; respondent
carried this burden. Also, in part I.C. of this opinion
respondent had the burden of proving, by clear and convincing
evidence, the amounts of petitioners’ underpayments of tax for
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