- 40 -
Mrs. Black is not liable for the accuracy-related penalty
imposed by section 6662(a) because the underpayments of tax for
taxable years 1991 and 1992 are due to fraud by Mr. Black. Sec.
6662(b); Zaban v. Commissioner, T.C. Memo. 1997-479; Aflalo v.
Commissioner, T.C. Memo. 1994-596; Minter v. Commissioner, T.C.
Memo. 1991-448.
We have considered all of petitioners’ contentions, and, to
the extent they are not addressed herein, they are irrelevant,
moot, or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: March 27, 2008