- 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.
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