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The issues remaining for decision are:2
(1) Are petitioners liable for each of the years 1986,
1987, and 1988 for the additions to tax for fraud under section
6653(b)(1)? We hold that they are for 1986 and 1987 and that
they are for 1988 to the extent stated herein.
(2) Did respondent make a computational error in determin-
ing petitioners' unreported gross receipts for 1988? We hold
that respondent did.
(3) Are petitioners liable for each of the years 1986,
1987, and 1988 for the addition to tax for a substantial under-
statement of income tax under section 6661(a)? We hold that they
are for 1986 and 1987 and that they are for 1988 to the extent
stated herein.
FINDINGS OF FACT3
Some of the facts have been stipulated and are so found.
2 Petitioners have conceded all of the determinations in the
notice of deficiency (notice) for the years at issue except the
issues stated, an issue as to whether the respective periods of
limitations for 1986 and 1988 have expired, and computational
issues for 1988 involving a disallowed medical expense deduction
and self-employment tax. Our resolution of the period of limita-
tions issue for 1986 and 1988 flows automatically from our
findings with respect to the issue regarding the additions to tax
for fraud for those years. See sec. 6501(c)(1). Our resolution
of the computational issues for 1988 flows automatically from
petitioners' concessions on other issues and our finding with
respect to the issue regarding an alleged computational error
involving petitioners' unreported gross receipts for that year.
3 Unless otherwise indicated or needed for clarity, our Findings
of Fact and Opinion pertain to 1986, 1987, and 1988, the years at
issue.
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