David W. Hill - Page 21

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               We conclude that the record contains clear and convincing              
          evidence of petitioner's intent to conceal, mislead, or otherwise           
          prevent the collection of taxes on the unreported income for the            
          years in issue.  We hold that the understatements of tax                    
          attributable to the unreported income from Mr. Hall were due to             
          fraud.  Petitioner has not established that any portion of the              
          underpayment is not due to fraud.  See sec. 6663(b).                        
          Accordingly, we sustain respondent's determination that                     
          petitioner is liable for the fraud penalties.                               


                                                  Decision will be entered            
                                             under Rule 155.                          


























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