Meri R. and William R. Kaufman - Page 10

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          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.                  

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