WANG v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for 1987 of $57,091, additions to tax for fraud under section 6653(b)(1)(A)1 and (B) of $42,818 and 50 percent of the interest due on $57,091, respectively, and an addition to tax for substantial understatement of tax under section 6661 of $14,273.

In the answer, respondent asserted additions to...