Yu-Yang Wu - Page 26




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          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.                          

























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