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As mentioned above, if the Commissioner establishes
that any portion of an underpayment is attributable to
fraud, then the entire underpayment is treated as
attributable to fraud, except with respect to any portion
of the underpayment which the taxpayer establishes (by a
preponderance of the evidence) is not attributable to
fraud. See sec. 6663(b). In this case, petitioners have
not established that any portion of the underpayment in
each of the years in issue is not attributable to fraud.
See id. Specifically, petitioners have not established
that the portion of the underpayments relating to the
payments from Sing-Sing, Gerre Trans, Richman & Sons,
and Camden City Probation is not attributable to fraud.
We also agree with respondent that Mrs. Vetrano played
a role in her husband’s fraudulent scheme and that some
part of the underpayment for 1993 is due to her fraud.
See sec. 6663(c). She knew of her husband’s activities
in connection with his automobile parts business involving
BMAP during the years in issue. She was aware of the
payments received from BMAP during 1993, and she played an
important part in converting the checks received from BMAP
to cash. She oversaw payment of the couple’s monthly bills
and deposited only the amount of cash necessary to pay the
couple’s monthly bills. Accordingly, we sustain
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