Carlye A. Christianson - Page 21




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          years 1985 through 1990, which she believed to be owing, by                 
          conduct intended to conceal, mislead, or otherwise prevent the              
          collection of such tax.  We further find on that record that                
          petitioner is liable for (1) the additions to tax for fraud                 
          (a) under section 6653(b)(1) and (2) for 1985, (b) under section            
          6653(b)(1)(A) and (B) for 1986 and 1987, and (c) under section              
          6653(b)(1) for 1988 and (2) the additions to tax under section              
          6651(f) for 1989 and 1990, as determined by respondent in the               
          notices.                                                                    
               To reflect the foregoing,                                              
                                             Decision will be entered for             
                                        respondent.                                   



























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