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YATES v. COMMISSIONER

Docket No. 21603-88.

57 T.C.M. 690 (1989)

T.C. Memo. 1989-285

Paul W. Yates v. Commissioner.

United States Tax Court.

Filed June 13, 1989.

Attorney(s) appearing for the Case

Paula M. Junghans, 36 S. Charles St., Baltimore, Md., for the petitioner. Elizabeth S. Henn, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

After concessions, the only remaining question is whether respondent has met the burden of showing by clear and convincing evidence that petitioner committed fraud, and is liable for additions to tax under section 6653(b).1 Specifically, the issue for decision is whether petitioner, virtually all of whose income was subject to withholding...

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