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On September 4, 1996, respondent sent a separate notice to
Ms. Drummond and to Mr. Drummond. Respondent determined, inter
alia, in the notice issued to Ms. Drummond that she received
nonemployee compensation from ABC during 1983 and 1984 which she
did not report for those years, that Ms. Drummond is liable for
1984 for the addition to tax for failure to make estimated tax
payments, and that she is liable for each of the years 1983 and
1984 for the additions to tax for fraud under section 6653(b)(1)
and (2) on the underpayment of tax for each such year. Respon-
dent determined, inter alia, in the notice issued to Mr. Drummond
that he received nonemployee compensation from ABC during 1983
and 1984 which he did not include in Schedule C of his return for
each of those years and that Mr. Drummond is liable for each of
the years 1983 and 1984 for the additions to tax for fraud under
section 6653(b)(1) and (2) on the underpayment of tax for each
such year.
OPINION
Each petitioner bears the burden of proving that all the
determinations in the respective notices, except the additions to
tax for fraud, are in error. See Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). Neither petitioner appeared
at the trial of these cases.4 On the record before us, we find
4 The Court nonetheless afforded each petitioner the oppor-
tunity to file a brief, either separately or jointly. They
(continued...)
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