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$2,341 for fiscal year 1987, and a net operating loss
carryforward of $2,341 for fiscal year 1988.
Respondent determined that petitioner did not have a net
operating loss for fiscal year 1987 and that petitioner had no
carryforward to fiscal year 1988 because respondent's adjustments
to petitioner's 1987 gross receipts eliminated the claimed net
operating loss.
Because of our holdings that petitioner had unreported gross
receipts and unreported interest income for 1987, petitioner did
not have a net operating loss, and thus we sustain respondent's
determination on this issue.
E. Fraud
Respondent determined that petitioner is liable for
additions to tax for fraud for fiscal years 1987 and 1988.
Respondent has the burden of proving fraud by clear and
convincing evidence. Sec. 7454(a); Rule 142(b). The existence
of fraud is a question of fact to be decided by consideration of
the entire record. Parks v. Commissioner, 94 T.C. 654, 660
(1990); Gajewski v. Commissioner, 67 T.C. 181, 199 (1976), affd.
without published opinion 578 F.2d 1383 (8th Cir. 1978).
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