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of the years at issue. The expenses were "just so far out of
line" with the revenue that Nyden asked petitioner if there was
any additional income from the farm. Petitioner responded that
there was $15,000 of additional income. Petitioner provided no
explanation of the source of the $15,000 of additional income.
We conclude that petitioner's records did not reflect accurately
his income and expenses.
We have no evidence that petitioner attempted to conceal any
particular assets. However, given respondent's net worth
analysis and petitioner's various business activities, we find
that petitioner concealed substantial amounts of cash that passed
through his hands and never appeared in his records or Forms
1040.
We find petitioner's explanations of the circumstances
surrounding the alleged cash hoard to be implausible and
inconsistent. Petitioner made little attempt to explain his
financial activities. To the extent he did so, we find those
explanations vague and inadequate.
Petitioners filed tax returns for the years in issue, but
the net worth analysis indicates substantial unreported income.
Petitioner also pled guilty to criminal charges of willfully
making and subscribing to a materially false Federal income tax
return for the taxable year 1985.
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