- 19 - behavior concerning his calculation of tithing and in reporting petitioners' income on the bank loan application was inconsistent with the reporting of petitioners' income on the tax returns for the years under consideration. (4) Intent to Mislead Misleading statements to an investigating agent may be evidence of fraud. See Gajewski v. Commissioner, 67 T.C. 181, 200 (1976), affd. without published opinion 578 F.2d 1383 (8th Cir. 1978). Petitioner misled Ms. Bellamy when he provided her with details of his income. During the audit, Ms. Bellamy indicated to petitioner the importance of obtaining all relevant information so that she could reconstruct petitioners' income. Petitioner refused to permit Ms. Bellamy to review petitioners' 1983 Federal income tax return. Petitioner claims that petitioners provided Ms. Bellamy with the brown books for the years under consideration at the first audit meeting, and that she took the books with her and later returned them. He further contends that his preparation of a mileage log, completed during the audit and at Ms. Bellamy's recommendation, is proof that the brown books were handed over to her. But he later claimed that the brown books were destroyed by his children, and expressed a belief that it was useless to keep records for longer than 3 years. It took almost 2 years before Ms.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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