Benjamin and Sallie Campfield - Page 25

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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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Last modified: May 25, 2011