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for petitioners’ family and what portion for the employees.
Thus, we are unable to estimate an amount deductible under
section 162(a). See Cohan v. Commissioner, 39 F.2d 540, 543-544
(2d Cir. 1930); Vanicek v. Commissioner, 85 T.C. 731, 742-743
(1985).
Petitioners challenge several other aspects of respondent’s
net worth computation. Many of petitioners’ arguments confuse
benefits provided by an employer to an employee with those
provided by a self-employed individual to himself. Additionally,
petitioners attempt to attribute some payments to Frank Black,
Inc. However, Frank Black, Inc., did not have any bank or other
accounts in 1992, nor did it transact any business or have any
employees.
B. Proof That the Underpayment Was Due to Fraud
Section 6663 imposes a penalty equal to 75 percent of the
portion of any underpayment which is attributable to fraud. Sec.
6663(a). The penalty in the case of fraud is a civil sanction
provided primarily as a safeguard for the protection of the
revenue and to reimburse the Government for the heavy expense of
investigation and the loss resulting from a taxpayer’s fraud.
Helvering v. Mitchell, 303 U.S. 391, 401 (1938). Fraud is
intentional wrongdoing on the part of the taxpayer with the
specific purpose to evade a tax believed to be owing. McGee v.
Commissioner, 61 T.C. 249, 256 (1973), affd. 519 F.2d 1121 (5th
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