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of the underpayment of tax if any part of the underpayment is
attributable to fraud. Section 6653(b)(2) provides for an
addition to tax (in addition to the addition under section
6653(b)(1)) in an amount equal to 50 percent of the interest
payable under section 6601 with respect to the portion of the
underpayment that is attributable to fraud. For purposes of
section 6653(b)(2), interest is computed for the period beginning
on the last day prescribed for payment of the underpayment
(without regard to extensions) and ending on the earlier of the
date of assessment or payment of the tax (the statutory period).
For taxable years 1986 and 1987, section 6653(b)(1)(A)
provides for an addition to tax in an amount equal to 75 percent
of the portion of the underpayment that is attributable to fraud.
Section 6653(b)(1)(B) provides for an addition to tax (in
addition to the addition under section 6653(b)(1)(A)) in an
amount equal to 50 percent of the interest payable under section
6601 for the statutory period with respect to the portion of the
underpayment that is attributable to fraud.
For taxable year 1988, section 6653(b)(1) provides for an
addition to tax in an amount equal to 75 percent of the portion
of the underpayment that is attributable to fraud. Section
6653(b)(2) provides that, if the Secretary (Commissioner)
establishes that any portion of the underpayment is attributable
to fraud, the entire underpayment is treated as attributable to
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