- 36 - 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.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36Last modified: November 10, 2007