- 36 - reported on his returns; that he ignored his attorneys' advice concerning the proper reporting of his commissions for Federal income tax purposes; and that he intended to conceal his receipt of the commissions in an attempt to evade Federal income tax. Petitioner's attempt to combat this overwhelming evidence against him with inconsistent and false explanations is further evidence of his fraud. The same is true with respect to petitioner's attempt to place the blame on Finley Kumble for his tax problems. v. Attempt to Conceal Activities Petitioner used nominees to conceal his ownership interest in CAI. He used a third party to withdraw substantial funds for himself and to pay his creditors as part of a scheme to avoid paying taxes on his earned commissions. We find both of these actions to be indicia of fraud. vi. Other Factors a. Petitioner's Sophistication A taxpayer's sophistication and experience are relevant in determining fraudulent intent. Stephenson v. Commissioner, 79 T.C. 995, 1006 (1982), affd. 748 F.2d 331 (6th Cir. 1984). Petitioner was a sophisticated and experienced businessman, especially in the international arena. We find this factor to be evidence of fraud under the facts contained herein. b. Withholding Information From Tax Preparer Petitioner's 1980 through 1982 returns contained many false statements and/or failed to report relevant information. The 1980 and 1981 returns stated erroneously that petitioner did notPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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