- 8 - produced a loss; however, respondent’s reconstructions revealed that the activity had, in fact, produced a profit. We accordingly hold that respondent has shown by clear and convincing evidence that petitioners’ understatement of income was fraudulent. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011