Charles L. Fields and Barbara S. Fields - Page 36

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          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 not            



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