- 11 - include: (1) Understating income, (2) maintaining inadequate records, (3) failing to file tax returns, (4) having implausible or inconsistent explanations of behavior, (5) concealing assets, (6) failing to cooperate with tax authorities, (7) engaging in illegal activity, (7) creating false documents or records, (8) dealing in cash, and (9) overstating deductions. See Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th Cir. 1986) affg. T.C. Memo. 1984-601; Meier v. Commissioner, 91 T.C. 273, 297-298 (1988); Estate of Temple v. Commissioner, 67 T.C. 143, 161 (1976). Petitioner's deemed admissions contain numerous indicia of her fraudulent intent to evade taxation with respect to each of the taxable years in issue. For example, the facts deemed admitted establish the following: Paragraph 26. Petitioner's failure to maintain complete and accurate records of her income-producing activities and her failure to produce complete and accurate records to the respondent in connection with the examination of petitioner's income tax returns for taxable years 1987 and 1988 was fraudulent with the intent to evade tax. Paragraph 32. For both 1987 and * * * 1988, petitioner fraudulently and with intent to evade tax deducted personal items as business expenses, deducted items she could not substantiate and claimed expenses that were not ordinary and necessary business expenses pursuant to section 162. Paragraph 33. During 1987 and 1988, the petitioner engaged in a pattern of conduct which demonstrates that she intentionally and knowingly failed to report substantial income in both years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011