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8. Attempting To Conceal Illegal Activities
Attempting to conceal illegal activities is indicative of
fraud. Id.
Petitioner went to great lengths to conceal her illegal
activities. Those efforts included taking part in the bankruptcy
scheme, concealing her beneficial ownership in certain entities
connected therewith, and using offshore bank accounts.
This factor weighs against petitioner.
9. Other Considerations
Petitioner is well educated and intelligent. She also is
deeply involved in every aspect of her business affairs and has
substantial experience with business, finance, corporations,
lawyers, and accountants.
10. Conclusion
Our analysis above concludes that seven of the eight factors
weigh against petitioner and that the remaining factor is
neutral. On the basis of our detailed review of the facts and
circumstances of this case, in conjunction with our analysis of
the eight factors mentioned above and our “other considerations”,
we conclude that respondent has clearly and convincingly proven
that petitioner filed her 1996 return intending to conceal,
mislead, or otherwise prevent the collection of tax.
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