- 21 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Last modified: May 25, 2011