- 278 - $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 thePage: Previous 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 285 286 287 Next
Last modified: May 25, 2011