Carl C. Poston III and Sherea A. Poston - Page 8




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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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