- 54 - the fraud penalty pursuant to sec. 6663 on the portion of the underpayment attributable to the constructive dividends and the income from self employment. Respondent concedes that Mrs. Cordes is not liable for that penalty.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54
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