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based on the source of receipts. Also, among the records seized
by respondent’s agents was an adding machine tape on which Mrs.
Karcho had labeled the unreported monthly cash tallies as “pocket
money”.
We hold that respondent has established by clear and
convincing evidence that the underpayments in each of the years
in issue are attributable to the fraud of each petitioner and
that petitioners have not established that any portion of such
underpayments is not attributable to fraud. Accordingly, the
period for assessment with regards to those years remains open.
See sec. 6501(c)(1); Sisson v. Commissioner, T.C. Memo. 1994-545
(fraud for purposes of section 6501(c) is the same as fraud for
penalty purposes), affd. without published opinion 108 F.3d 339
(9th Cir. 1996).
We have considered all of petitioners’ remaining arguments
and, to the extent not addressed herein, find them meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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