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omitted income was not subject to tax. The record is devoid of
evidence that petitioners, or either of them, asked any tax
adviser or tax-return preparer about any of the omitted items.
Petitioners do not even take the trouble to describe to us what
they claim to be the “reasonable cause for their actions.”
We have ignored Zenaida’s check-cashing activities because
(1) the amounts of her fees for any year are uncertain and
trivial, and (2) they may in any event be adequately dealt with
under respondent’s use of the bank deposits method.14
We hold, for respondent, that petitioners failed to show by
a preponderance of the evidence that the deficiency for 1991 or
1992 is less than what respondent determined, as modified by
respondent’s concessions and our observations in the footnotes to
table 2, supra.
We hold, for respondent, that petitioners failed to show by
a preponderance of the evidence that any part of the underpayment
for 1991 or 1992 was not due to fraud.
III. 1993
For 1993, respondent determined that (1) petitioners have a
tax deficiency resulting from their failure to report $10,618 of
income, and (2) petitioners are liable for 20-percent negligence
14We assume that the cashed checks have been properly
accounted for under the instant case’s application of the bank
deposits method. See supra table 2. Petitioners have not
suggested otherwise.
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