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petitioner Janet Wade nor petitioners' income tax return preparer
was informed of the reductions made by petitioner.
Petitioner's alleged justification for the reductions on the
summary sheets (namely, to net repair and maintenance expenses
against rental income) is contradicted by the separate deductions
claimed on petitioners’ returns for such expenses. Petitioners'
testimony that the separate deductions for repair and maintenance
expenses were claimed on their returns by their income tax return
preparer without their knowledge is not believable, and we reject
such testimony.
For 1982 and 1983, petitioners maintained inadequate records
with regard to their apartment rental business.
In 1983, petitioners purchased certificates of deposit
totaling $400,000, while petitioners reported on their joint
Federal income tax returns no taxable income for both 1982 and
1983.
Also, for 1982 and 1983, petitioner pleaded guilty to filing
false Federal income tax returns.
On the evidence before us, we conclude that for 1982 and
1983 petitioner intentionally attempted to evade petitioners’
correct joint Federal income tax liabilities, and we sustain
respondent's imposition of the fraud additions to tax against
petitioner.
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