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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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