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             Fraud Penalty                                                            
                  Respondent determined that petitioner fraudulently                  
             omitted income from his individual 1991 and 1992 returns on              
             which there are underpayments of $10,488, and $10,600,                   
             respectively.  Respondent determined that the entire                     
             underpayment for each of the years 1991 and 1992 is                      
             attributable to fraud.  Therefore, respondent determined                 
             that petitioner is liable for civil fraud penalties under                
             section 6663 of $7,866 and $7,950, respectively.                         
                  Respondent also determined that petitioners                         
             fraudulently omitted income from their joint 1993 return                 
             on which there is an underpayment of $32,114.  As to 1993,               
             respondent also determined that the entire underpayment                  
             is attributable to fraud and that some part of the                       
             underpayment is due to the fraud of both petitioners.                    
             Therefore, respondent determined that petitioners are both               
             liable for a civil fraud penalty under section 6663 of                   
             $24,086 for 1993.                                                        
                  Section 6663(a) provides that, if any part of an                    
             underpayment is due to fraud, there shall be added to the                
             tax an amount equal to 75 percent of the portion of the                  
             underpayment which is attributable to fraud.  The                        
             Commissioner bears the burden of proving by clear and                    
             convincing evidence:  (1) An underpayment exists; and (2)                
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