-39-
_______________________
In general, and in the case of each of the arrangements
described supra, Robert provided the initiating ideas and the
force necessary to put the arrangements into effect, while Monica
provided or oversaw the necessary administrative and technical
work to carry out the arrangements.
For each of the years 1980, 1981, and 1982, respondent has
shown by clear and convincing evidence that petitioners had an
underpayment of income tax required to be shown on their joint
tax return; the underpayment for each of these years was due to
Robert's fraud.23
OPINION
Respondent contends that (1) petitioners underpaid their
taxes for 1980 through 1982, (2) petitioners' underpayments for
these years are due in whole or in part to Robert's fraud, and
thus (3) Robert is liable for the fraud additions to tax under
section 6653(b). Robert contends that he never had any intent to
deceive the Federal Government.
We agree with respondent.
23 In the instant case we are not called upon to determine
whether and, if so, then to what extent, any of these
underpayments were due to Monica's fraud. Supra note 3. Any
such fraud on Monica's part does not diminish Robert's fraudulent
responsibility for the underpayments.
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