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“passthrough” entity, yet did not provide any evidence of where
this income was “passed on” to.
Based upon these indicia, we hold that respondent has
carried the burden of showing by clear and convincing evidence
that petitioner’s failure to report income for 1993, 1994, and
1995 was fraudulent with the intent to evade tax. Petitioner, on
the other hand, has failed to show that any portion of its
underpayment was not due to fraud. Accordingly, we sustain
respondent’s determination that petitioner is liable for the
penalties for fraud under section 6663(a) for all the years under
consideration.
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011