- 53 - 1984 and 1985 corporate Federal income tax returns, and that Elvin is not sophisticated in tax matters. In support of the contention that both Elvin and YOC filed fraudulent Federal income tax returns for the years in issue, respondent argues that the correct taxable income on each of the individual and corporate tax returns in question was significantly underreported, that Elvin had the mental capacity in 1983 through 1986 to form fraudulent intent, that Elvin for 1983 was convicted under section 7201 of Federal income tax evasion and under section 7206(2) of filing a false and fraudulent corporate Federal income tax return for YOC, that the same activities and course of conduct that were present in 1983 and that formed the factual basis for Elvin's convictions for 1983 were continued by Elvin in 1984, 1985, and 1986, that Elvin followed a pattern of consistent underreporting of income, that Elvin caused YOC to pay many of his personal expenses and to purchase personal assets, and that YOC followed a pattern of consistent underreporting of income. Based on our many findings and conclusions herein sustaining respondent's substantive tax adjustments, it is clear that respondent has shown that very substantial underreporting of income and underpayments of Federal income taxes occurred on Elvin's and on YOC's Federal income tax returns for the years at issue.Page: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
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