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ULTIMATE FINDINGS OF FACT
1. Petitioner substantially understated his taxable income
for the years 1972 through 1977.
2. Petitioner substantially overstated his business
expenses, losses, and deductions for the years 1973 through 1981.
3. The underpayments of income taxes which were required to
be included in petitioner's Federal income tax returns for the
years 1972 through 1976 were due to fraud with intent to evade
tax.
4. The assessment and collection of petitioner's Federal
income taxes for 1972 are not barred by the statute of
limitations.
5. Petitioner's omission of substantial amounts of income
and overstatement of expenses and deductions for 1977 were due to
negligence or intentional disregard of rules and regulations.
6. Petitioner's overstatements of business expenses,
deductions, and losses for the years 1978 through 1981 were due
to negligence or intentional disregard of rules and regulations.
OPINION
It is no doubt apparent that these cases involve some
measure of factual and legal complexity. That complexity is
reflected in the magnitude of the record and is exacerbated by
the contentions and arguments of the parties. Not surprisingly,
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