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altogether because, she stated, she “worked too damn hard for
this money to lose it to taxes”. When her attorneys could not
find a legal way to accomplish her goal, she became angry and
instructed them to falsify BBL’s returns so that she could
underreport its income and hers.
Petitioner’s handling of the Sanwa account displays yet more
evidence of her fraudulent intent. For the 3 years that the
account was in existence, petitioner made not one transfer,
withdrawal, or other transaction that might have brought the
account to the attention of respondent. She wrote only one check
on the account for the expense of printing checks for the
account. When the account had served its fraudulent purpose, it
was closed with one large transfer of funds to an offshore
account. These transactions, taken together, constitute a
methodical and sophisticated attempt to conceal income and
assets.
This factor weighs against petitioner.
6. Failing To Cooperate With Tax Authorities
Failure to cooperate with tax authorities is indicative of
fraud. Id.
Petitioner has been uncooperative with both respondent and
this Court as to the matter at hand. She failed on numerous
occasions to respond timely to requests from respondent. She
flouted Rule 91(f) and the Court’s order of November 18, 2003,
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