Lee F. Haney, Sr., and Jean C. Haney, a.k.a. Jeanie Haney - Page 36




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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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