-3-
b. Whether, as petitioners contend, $90,000 was
stolen from them in January 1985. We hold that it was not.
c. Whether respondent overstated petitioners' 1985
personal expenses by $25,060. We hold that respondent did not.
d. Whether petitioners had $40,000 in cash on hand on
December 31, 1983, 1984, 1985, 1986, and 1987, as respondent
contends; about $385,000, $340,000, $250,000, $182,500, $123,000,
as petitioners contend; or some other amount. We hold that they
had $40,000 in cash on hand on December 31, 1983, 1984, 1985,
1986, and 1987.
3. Whether petitioners had unreported income of $221,961
in 1983, $45,598 in 1984, $8,608 in 1985, $69,788 in 1986, and
$29,872 in 1987, as respondent contends; zero for 1983 to 1987,
as petitioners contend; or some other amount. We hold that
petitioners had unreported income of $82,961 in 1983, $45,598 in
1984, $8,608 in 1985, $60,788 in 1986, and $29,822 in 1987.
4. Whether petitioners are liable for additions to tax for
fraud under section 6653(b) for tax years 1983 to 1987. We hold
that they are.
5. Whether the statute of limitations bars assessment of
tax for the years in issue. We hold that it does not.
6. Whether petitioners are liable for additions to tax for
substantial understatement of tax under section 6661. We hold
that they are for the years they substantially underpaid tax.
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