Jacob and Yehiella Kalo - Page 13

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            fraudulent intent to conceal the income.  We disagree.  There is                              
            ample evidence in the record that petitioner did in fact make                                 
            attempts to conceal his interest income.  Question 10 on Schedule                             
            B of petitioners' tax returns for the years in issue asks:  “At                               
            any time during the tax year, did you have an interest in or a                                
            signature or other authority over a financial account in a                                    
            foreign country (such as a bank account, securities account, or                               
            other financial account)?”  For the years 1986 and 1987,                                      
            petitioner answered this question in the negative.  For the years                             
            1988 and 1989, petitioner answered yes to this question but only                              
            listed a bank account in Israel.  In signing the returns,                                     
            petitioner represented, under penalty of perjury, that he                                     
            examined the schedules accompanying the returns and that they                                 
            were “true, correct, and complete” to the best of his knowledge.                              
            His answers to this question indicate an attempt to conceal his                               
            foreign accounts which is a strong indication of fraud.                                       
                  e.  Intent To Mislead                                                                   
                  False and inconsistent statements to respondent's agents                                
            during the course of their investigation indicate fraudulent                                  
            intent.  Grosshandler v. Commissioner, 75 T.C. 1, 20 (1980).                                  
            Petitioner failed to mention any Canadian bank accounts when                                  
            questioned about foreign accounts and when specifically                                       
            questioned about Canadian accounts only mentioned that he thought                             
            that he had a Canadian account, but that the money was his                                    






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