- 13 - 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 hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011