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The facts admitted establish a pattern of fraudulent
conduct, including failure to report income and elaborate efforts
to conceal that income and to prevent the collection of taxes on
that income. The admitted facts thus constitute clear and
convincing evidence of fraud for all of the years in issue, and
respondent's burden of proof has been satisfied.
Because the matters admitted are sufficient to satisfy
respondent's burden of proving fraud and there exists no genuine
issue of any material fact, respondent's Motion for Summary
Judgment will be granted. Rule 121(b).
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011