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the additions we determine in this case and the unpaid
underpayments of tax reflected by petitioner’s amended returns
for 1984 and 1986. See 11 U.S.C. sec. 523(a)(1)(C)
(1994).
The issue for our decision is whether petitioner is liable
for the addition to tax for fraud. The fraud addition was
enacted to protect the revenue and to reimburse the Government
for the heavy expense of investigation and the loss resulting
from the taxpayer's fraud. Helvering v. Mitchell, 303 U.S. 391,
401 (1938). Before petitioner can be held accountable for the
fraud addition, respondent must prove by clear and convincing
evidence that: (1) There was an underpayment of tax, and (2)
some part of the underpayment resulted from fraud. Rule 142(b);
Bagby v. Commissioner, 102 T.C. 596, 607 (1994).
In the case of income tax for which a timely return was
filed, an underpayment includes a deficiency as defined in
section 6211. Sec. 6653(c)(1). Section 6211 defines a
deficiency as “the amount by which the tax imposed * * * exceeds
* * * the amount shown as the tax by the taxpayer upon his
return”. However, any amount of additional tax shown on an
amended return filed after the due date of the return is also a
deficiency for the purpose of determining an underpayment. Sec.
301.6653-1(c), Proced. & Admin. Regs. In this case, respondent
has not determined a deficiency with respect to petitioner, but
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