-2- section 6663 for 1997 and 1998 (the years at issue).2 Respondent determined that petitioner Patricia B. Paterson (Mrs. Paterson) was liable for a $53,168 deficiency and a $39,876 fraud penalty for 1997. For 1998, respondent determined that Mrs. Paterson was liable for a $16,402 deficiency and a $12,301.50 fraud penalty. Respondent determined that petitioner George M. Paterson (Mr. Paterson) was liable for a $125,280 deficiency and a $93,960 fraud penalty for 1997. For 1998, respondent determined that Mr. Paterson was liable for a $88,257 deficiency and a $66,192.75 fraud penalty. There are three issues for decision. The first issue is whether petitioners understated their income in the amounts respondent determined for the years at issue. We hold that they did. The second issue is whether petitioners are liable for the fraud penalties for the years at issue. We hold that they are. The third issue is whether the limitations period bars respondent from assessing petitioners’ taxes for the years at issue. We hold that it does not. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the accompanying exhibits are 2All section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007