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preparation of her tax returns for the earlier years and would
not resume work until fees in arrears had been satisfied and a
retainer of $10,000 was paid. Payments totaling $80,236 were
made during 1989 and 1990 to Eisner & Lubin for professional
services. Eisner & Lubin performed an additional $40,000 worth
of services for which petitioner was billed. Eisner & Lubin did
not prepare any requests for extension or tax returns for
petitioner or any of the nominee corporations for any year
subsequent to 1980.
OPINION
The sole issue for decision is whether petitioner is liable
for the additions to tax for fraud under sections 6653(b)(1)(A)
and (B) for the 1987 taxable year and section 6653(b)(1) for the
1988 taxable year and the additions to tax for fraudulent failure
to file timely income tax returns under section 6651(f) for the
1989 and 1990 taxable years.
Section 6653(b)(1)(A) and section 6653(b)(1), as in effect,
respectively, for the 1987 and 1988 returns in this case impose
an addition to tax equal to 75 percent of the portion of the
underpayment which is attributable to fraud. Section
6653(b)(1)(B), as in effect for 1987, imposes a further addition
to tax equal to 50 percent of the interest payable under section
6601 with respect to the portion of the underpayment attributable
to fraud. If any portion of the underpayment is attributable to
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