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taxable income for the years in issue is clear and convincing.
Petitioners have not proven that any part of the underpayments in
dispute was not attributable to fraud. See sec. 6663(b). Upon
consideration of the entire record, we conclude that petitioners
are liable for the fraud penalty determined by respondent under
section 6663(a).
We have considered the arguments of the parties that were
not specifically addressed in this opinion. Those arguments are
either without merit or irrelevant to our decision.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007