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fraudulent with the intent to evade tax. See sec. 6501(c)(1).
As discussed above, respondent failed to prove by clear and
convincing evidence that petitioner committed fraud. We hold
that respondent is barred by the statute of limitations from
assessing and collecting tax and the addition to tax for
valuation overstatement for the years in issue.
To reflect the foregoing,
Decision will be entered
for petitioners.
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Last modified: May 25, 2011