- 48 - stock was received. Also, petitioner's receipt of the stock in payment for legal services was disguised as a purchase and sale. Respondent has established by clear and convincing evidence that petitioner fraudulently underreported and underpaid his Federal income taxes for 1987 and 1988. We conclude that the fraud addition to tax applies to the entire underpayment for each year. Sec. 6653(b)(2). Because petitioner fraudulently filed his 1987 and 1988 Federal income tax returns, the period of limitations does not bar assessment of income tax for those years. Sec. 6501(c)(1). Petitioner makes no separate argument for 1987 and 1988 regarding the substantial understatement addition to tax. In light of our findings and conclusions herein regarding petitioner’s failure to report his correct income for 1987 and 1988, we sustain respondent’s determination of the substantial understatement addition. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48
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