- 14 - rejected so often that no one who, like Burdett, claims to have researched the question could still sincerely believe that someone in Burdett’s circumstances was exempt from the tax laws. Id. at 229-230. C. Conclusion After reviewing all of the facts and circumstances, we conclude that petitioner’s Cheek defense is without merit and that respondent has proven by clear and convincing evidence that for each of the years in issue petitioner’s entire underpayment was attributable to fraud. Accordingly, we sustain the additions to tax and penalties for fraud. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
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