Anthony G. and Shirley A. Olbres - Page 59

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          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.                        





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