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tax returns for 1988 through 1992, respectively; (8) fraudulently
and with the intent to evade tax understated their taxable income
in the amounts of $54,565, $137,811, $96,049, $135,050, $284,935,
$301,132, and $241,608 for the tax years 1987 through 1993,
respectively; and (9) fraudulently understated and failed to pay
their income tax liabilities in the amounts of $9,921, $36,492,
$13,488, $28,619, $55,391, $40,029, and $87,539 for the tax years
1987 through 1993, respectively.
Based on the foregoing, we conclude that respondent has
satisfied the burden of proving, by clear and convincing
evidence, that the entire underpayment of tax for each of the
years in issue was due to fraud. Accordingly, we sustain
respondent's determination that petitioners are liable for
additions to tax for fraud for the years in issue.
To reflect the foregoing,
An order granting Respondent's
Motion for Partial Summary Judgment
will be issued.
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