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the assessment and collection of their Federal income taxes for
such years are not barred by the statute of limitations. See
sec. 6501(c)(2).
Issue 33. The Liabilities of Kanter, Ballard, and Lisle for
Additions to Tax for Negligence
OPINION
The Court has held that Kanter is liable for fraud additions
to tax for the years 1978 through 1984 and for the years 1986
through 1989. The Court has also held that Ballard is liable for
the fraud addition to tax for the years 1975 through 1982, for
the year 1984, and for the years 1987 through 1989. The Court
has further held that Lisle is liable for the fraud addition to
tax for the year 1984 and the years 1987 through 1989.
In the notices of deficiency and/or in amended pleadings,
respondent also determined and/or asserted the additions to tax
for negligence or intentional disregard of rules or regulations
against Kanter under section 6653(a) with respect to activities
other than the Prudential activities as to which the Court has
concluded that the fraud addition to tax is applicable.63
Respondent agrees on brief that for years prior to 1986, if
the addition to tax for fraud is applicable, the amount of the
fraud addition to tax is calculated on the entire underpayment of
tax, including underpayments relating to nonfraudulent
63
See supra note 3 outlining the various versions of section
6653(a) in effect during the years at issue.
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