-35-                                          
          C.   Additions to Tax for Fraud Under Section 6653(b)                       
               1.   Background                                                        
               Respondent determined that petitioners are liable for                  
          additions to tax for fraud for 1983, 1984, 1985, 1986, and 1987.            
          For 1983, 1984, and 1985, if any part of a tax underpayment is              
          due to fraud, the addition to tax under section 6653(b)(1) is 50            
          percent of the underpayment, and the addition to tax under                  
          section 6653(b)(2) is 50 percent of the interest payable under              
          section 6601 for that part of the underpayment that is due to               
          fraud.  For 1986 and 1987, the addition to tax for fraud under              
          section 6653(b)(1)(A) is 75 percent of the part of the                      
          underpayment that is due to fraud, and the addition to tax under            
          section 6653(b)(1)(B) is 50 percent of the interest payable under           
          section 6601 for that part of the underpayment that is due to               
          fraud.  Under section 6653(b)(1)(A) and (B), if respondent                  
          establishes that part of the underpayment is due to fraud, the              
          additions to tax apply to the entire underpayment except with               
          respect to any part that petitioners show is not due to fraud.              
          Sec. 6653(b)(2).                                                            
               Respondent has the burden of proving fraud by clear and                
          convincing evidence.  Sec. 7454(a); Rule 142(b).  For purposes of           
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