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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.
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