- 10 -
evade taxes. We therefore conclude that respondent has satisfied
the burden of proving, by clear and convincing evidence, that the
entire underpayment of tax for each of the years in issue was due
to fraud on her part. We sustain respondent’s determination that
Ms. Kaufman is liable for penalties under section 6663 for 1993,
1994, and 1995.
To reflect the foregoing,
An appropriate order
granting respondent’s motion
for partial summary judgment
as to petitioner Meri R.
Kaufman will be issued.
Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011