J.J. Zand - Page 206

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          $50,000.  The interest income alone earned on or deposited to the           
          foreign bank accounts in 1976 exceeded that amount.                         
               After Mr. Giffin prepared petitioner's income tax returns,             
          Mr. Giffin, petitioner, and others would review the returns,                
          including the individual items that made up the total numbers               
          shown on the returns.  If petitioner believed something on a                
          return was not correct, he would personally have it corrected.              
          Thus, petitioner signed the returns with knowledge of the                   
          substantial omissions of income from Lockheed, Ashland, and                 
          foreign bank accounts.                                                      
               By not informing his accountant and return preparer about              
          interest income earned on bank accounts outside the United                  
          States, by diverting the income he earned from Lockheed and                 
          Ashland to accounts in the names of All Patents, WHIP, and Diesel           
          Power, and by not recording all fees earned from Lockheed and               
          Ashland, petitioner clearly evaded the payment of substantial               
          portions of his income tax liabilities for the years 1972 through           
          1976.  Keeping this information from Mr. Giffin was an act of               
          concealment by petitioner.  Reliance upon an accountant to                  
          prepare accurate returns negates fraudulent intent only if the              
          accountant has been supplied with all the information necessary             
          to prepare the returns.  Estate of Temple v. Commissioner, 67               
          T.C. 143, 162 (1976).  Here petitioner was responsible for the              







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