T.C. Memo. 1997-187
UNITED STATES TAX COURT
THOMAS G. ROOTS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19287-95. Filed April 21, 1997.
P underreported income from his rental and
insurance businesses during 1984, 1985, 1986, and 1987.
P did not keep records for either business, and he
commingled funds of each business with funds of the
other and with his personal funds. P received
commission checks from his insurance business, but he
reported on his tax returns only the commissions for
which he received Forms 1099, Miscellaneous Income.
P told rental tenants to mislead Internal Revenue
Service agents as to the amount of rent they paid to
him. P was convicted of willfully attempting to evade
or defeat income taxes under sec. 7201, I.R.C., for his
1987 taxable year and of willfully attempting to
interfere with the administration of internal revenue
laws in violation of sec. 7212(a), I.R.C.
Held: The currency deposits to P's bank account
for his 1984 and 1985 taxable years are taxable
deposits.
Held, further, P is liable for additions to tax
for fraud under sec. 6653(b)(1) and (2), I.R.C., for
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