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Petitioner’s educational background and his lack of training
in accounting and business do not preclude our imposition of the
fraud additions to tax.
We do not sustain the fraud additions to tax with respect to
petitioner Janet Wade for 1982 and 1983. The evidence does not
establish that petitioner Janet Wade participated in, or knew of,
petitioner's alterations to the summary sheets.
In light of our finding of fraud as to petitioner for 1982
and 1983, the period of limitations does not bar assessment of
deficiencies against petitioners for those years.
Section 6661 provides for an addition to tax where an
understatement in tax exceeds 10 percent of the tax required to
be shown on the return or $5,000. Sec. 6661. Petitioners have
made no separate argument regarding this addition to tax for 1982
and 1983, and we sustain respondent’s determination thereof.
For 1984, petitioner apparently argues that the copy of the
Form 1040 that he submitted to respondent in 1993 purportedly
represents a copy of petitioners’ 1984 joint Federal income tax
return that petitioner claims was actually filed in 1988. Thus,
petitioner argues that the period of limitations for 1984 had
expired by the time respondent mailed to petitioner on
December 15, 1993, the notice of deficiency for 1984.
Alternatively, petitioner argues that for 1984 he is entitled to
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