- 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.
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