- 6 - returns. Petitioner attempted to conceal the source and amount of the income that he realized from sales of illegal drugs by engaging in large cash purchases, acquiring assets through the use of nominees, and burying $315,000 in a cemetery. During 1993, in an effort to avoid prosecution for his illegal activities, petitioner acquired a false driver's license from the State of California. Petitioner fraudulently and with the intent to evade taxes filed income tax returns for 1992 and 1993 in which he omitted $751,823 and $400,260 in income from sales of illegal drugs, respectively. The underpayments of tax required to be shown on petitioner's 1992 and 1993 income tax returns are due to fraud with intent to evade income tax. Discussion Summary judgment is intended to expedite litigation and avoid unnecessary and expensive trials. Florida Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may be granted with respect to all or any part of the legal issues in controversy "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that a decision may be rendered as a matter of law." Rule 121(b); see Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994); Zaentz v. Commissioner, 90 T.C. 753, 754 (1988);Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011