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1994
Taxable Income as Corrected $ 61,750
Taxable Income as Reported (no return filed) (none)
Understatement of Taxable Income $ 61,750
ad). For the taxable year 1994, the petitioner’s
correct income tax liability, the income tax liability
he reported on his return for said year, and his
understatement of income tax liability for said year,
were as follows:
1994
Correct Income Tax Liability $ 24,002.00
Income Tax Liability Reported (no return filed) (none)
Understatement of Income Tax Liability $ 24,002.00
ae). Petitioner fraudulently, and with intent to
evade tax, filed an application requesting an automatic
extension that understated his estimated 1994 federal
income tax liability by over $23,000.00.
af). Petitioner fraudulently, and with intent to
evade tax, failed to report his gross receipts, failed
to report his taxable income, and failed to report his
income tax liabilities on a federal income tax return
for the taxable year 1994.
ag). Petitioner fraudulently, and with intent to
evade tax, used false entities and names to disguise
his receipt of income.
ah). Petitioner fraudulently, and with intent to
evade tax, relied extensively on cash transactions to
avoid a “paper trail” of his receipt of income.
ai). Petitioner fraudulently, and with intent to
evade tax, failed to maintain books and records of his
income-producing activities.
aj). Petitioner fraudulently, and with intent to
evade tax, attempted to conceal his 1994 expenditures
after he became aware of the audit of his 1994 year.
ak). Petitioner also, with intent to evade tax,
delayed and neglected to fully and timely satisfy his
admitted federal income tax liability for the 1993
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