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to revenue agents, and transfer of funds to undisclosed foreign
accounts establish the corporation’s fraudulent intent.
Petitioners failed to establish, pursuant to section 6663(b),
that any portion of the underpayment was not due to fraud.
Accordingly, ZMDI is liable for the section 6663(a) fraud penalty
relating to the entire underpayment of tax in 1990 through 1994.
Contentions we have not addressed are moot, irrelevant, or
meritless.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011