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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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