St. Luc Valbrun - Page 10

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               Respondent has shown by clear and convincing evidence that             
          petitioner’s entire $33,255 underpayment of tax was fraudulent              
          and that petitioner’s underpayment is subject to the penalty                
          under section 6663(a).                                                      

                                             Decision will be entered                 
                                        under Rule 155.                               



































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Last modified: May 25, 2011