- 59 - the revised 1988 underpayment that are attributable to the deductions that respondent disallowed are not due to fraud. We reject that contention. On the record before us, we find that petitioners failed to show, as they must under section 6653(b)(2), that the respective portions of the 1986 underpayment and the revised 1988 underpayment that are attributable to the deductions that respondent disallowed are not due to fraud. Based on the entire record before us, we find that petition- ers are liable for the additions to tax under section 6653(b)(1) with respect to the portion of the underpayment for 1986 that respondent determined is attributable to fraud and the revised 1988 underpayment.19 Issues on Which Petitioners Have the Burden of Proof Deficiency Determinations Petitioners concede the deficiency determination for each of the years at issue except for the portion of the deficiency for 1988 that is attributable to the claimed 1988 computational error. We have sustained petitioners' position with respect to that claimed error. Accordingly, we sustain respondent's defi- ciency determinations for the years at issue except for that portion of the 1988 deficiency that is attributable to the 1988 computational error. 19 We have considered all of petitioners' arguments not dis- cussed herein, and we find them to be without merit.Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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