- 26 - of action consciously undertaken both to avoid taxation and to avoid detection. Respondent has met his burden of showing by clear and convincing evidence that petitioner’s understatements of income were due to fraud. Petitioner offered no credible evidence to show that any portion of the understatements was not due to fraud. We sustain respondent’s determinations that petitioner is liable for the civil fraud addition to tax for 1988 and fraud penalties for 1989 and 1990. To reflect the foregoing and respondent’s concessions, Decision will be entered under Rule 155.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
Last modified: May 25, 2011