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v. Commissioner, supra at 665; Estate of Temple v.
Commissioner, 67 T.C. 143, 162-163 (1976); Burke v.
Commissioner, T.C. Memo. 1995-608.
We find that the circumstances of this case, taken
as a whole, clearly and convincingly establish that
petitioner acted with the requisite fraudulent intent,
and that the entire underpayment of tax for 1983 is
due to fraud, as determined by respondent. Accordingly,
we sustain respondent's determination that petitioner is
liable for the additions to tax for fraud prescribed by
section 6653(b)(1) and (2).
Addition to Tax for Substantial Understatement of Liability
Respondent also determined that petitioner is liable
for the addition to tax for substantial understatement of
liability prescribed by section 6661. Section 6661, as in
effect for 1983, imposed an addition to tax equal to 25
percent of any underpayment which is attributable to a
"substantial understatement of income tax". See Pallottini
v. Commissioner, 90 T.C. 498 (1988). A "substantial
understatement of income tax" is defined as any
understatement which exceeds the greater of 10 percent of
the tax required to be shown on the return for the taxable
year or $5,000. See sec. 6661(b)(1). Petitioner bears
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