- 7 - matters contained in the answer are petitioner's admissions that: (1) The omission of specific items of income for the years in issue is part of a 3-year pattern of intent to evade taxes; (2) petitioner understated taxable income in the amounts of $52,322 for 1985, $75,753 for 1986, and $111,195 for 1987; and (3) the deficiency for each of the years in issue is due to fraud with intent to evade taxes. Additionally, petitioner's conviction under section 7201 collaterally estops him from denying that there is an underpayment of his income tax and that some part of the underpayment is due to fraud for purposes of section 6653(b)(1)(A) and (B) for 1987. Rodney v. Commissioner, 53 T.C. 287, 305 (1960). The above-pleaded facts clearly establish that petitioner fraudulently underpaid his income taxes for the years in issue. Thus, we are satisfied that the additions to tax for fraud for the years in issue should be sustained by the entry of a default judgment against petitioner pursuant to Rule 123(a). To reflect the foregoing, An appropriate order will be issued, and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011