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after respondent filed a motion to impose sanctions. Respondent
had to resort to this method to obtain the necessary facts, due
to petitioner's efforts to conceal these facts. He did not
volunteer complete and truthful information.
In 1979, after petitioner had Mr. Dutton withdraw the
$610,000 from WHIP's bank account in Barclays Bank Bahamas, Mr.
Dutton informed respondent's agent, who was investigating
potential criminal liability, that the $610,000 would be reported
on petitioner's 1978 income tax return. However, there is no
attachment to the tax return disclosing the withdrawal, and the
income was not reported on petitioner's return. All in all, it
is our view that petitioner did not truly cooperate with
respondent's agents. We think he only did what he thought was
necessary to keep respondent's agents from discovering the true
sources of his fraud.
Accordingly, after considering all the facts and
circumstances present in this record, we have found, and hold,
that petitioner is liable for the additions to tax for fraud
under section 6653(b) on the amounts of the underpayments for the
years 1972, 1973, 1974, 1975, and 1976.
X. Issue 14--Statute of Limitations for 1972
Petitioner has affirmatively pleaded and contends that the
assessment of additional taxes for the year 1972 is barred by the
3-year statute of limitations. Sec. 6501(a). However, as
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