- 39 - Ahmed’s testimony lacked credibility and was replete with inconsistencies. Based on Ahmed’s pattern of understating his and K & M’s taxable income and of underpaying his and K & M’s Federal income tax liabilities, and the conduct described above, we conclude that respondent has established by clear and convincing evidence that both Ahmed and K & M acted willfully and with specific intent to underpay their correct Federal income tax due for each year in issue. Ahmed and K & M have not established that any portion of the tax deficiencies is not attributable to fraud. Accordingly, the entire individual and corporate Federal income tax deficiencies, as determined herein, are subject to the relevant fraud penalties under sections 6663(a) and 6651(f). We have considered all arguments made herein, and, to the extent not addressed, we conclude that they are without merit or are irrelevant. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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