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In conclusion, the deemed admissions by petitioner that he
understated income, concealed assets, dealt extensively in cash,
and was convicted for filing a false income tax return establish
by clear and convincing evidence that the underpayments of income
tax on his 1984 and 1985 income tax returns were due in their
entirety to fraud.
Respondent's motion for summary judgment will be granted.
To reflect the foregoing,
An appropriate order
will be issued, and decision will
be entered.
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Last modified: May 25, 2011