- 8 - Respondent has proven by clear and convincing evidence that petitioner fraudulently underpaid tax for 1989. Accordingly, the fraud penalty is justified in this case, and petitioner has not proven that any part of the underpayment is not attributable to fraud. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011