Court of Appeals for the Ninth Circuit January 11, 2001, No. 99-70911; Tax Ct. No. 14283-97 (Christianson v. Commissioner)

MEMORANDUM1

Appellant Carlye Christianson (“Chris-tianson”) appeals the tax court’s decision affirming the government’s assessment of tax fraud penalties against her under 26 U.S.C. §§ 6653(b) and 6651(f). Christian-son contends that the tax court erred in applying such penalties because the government failed to carry its burden of proving fraud by clear and convincing evidence.