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on that record that each petitioner 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 that each
petitioner has for each of those years.
To reflect the foregoing and the concession of respondent
with respect to Mr. Drummond for 1983,
Decision will be entered
for respondent in docket No.
26060-96.
Decision will be entered
under Rule 155 in docket No.
26077-96.
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