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diversion of large amounts of Forkston’s cash receipts for their
personal use was fraudulent with intent to evade tax. Further,
in paragraph 7 respondent alleges that, as a result of
petitioners’ diversion of part of Forkston’s cash receipts to
their personal use, petitioners understated their taxable income
and their tax liabilities by the amounts shown in table 1.
Table 1
Understatement of Understatement of
Year Taxable Income Tax Liability
1988 $43,114 $9,090
1989 82,582 20,791
1990 112,934 31,436
These are the same amounts as those in the notice of deficiency.
In paragraph 7 respondent also alleges that Anthony was convicted
under section 7206(2)3 for aiding and assisting in the filing of
false income tax returns for Forkston for 1988, 1989, and 1990.
3 SEC. 7206. FRAUD AND FALSE STATEMENTS.
Any person who--
* * * * * * *
(2) Aid or assistance.--Willfully aids or assists
in, or procures, counsels, or advises the preparation
or presentation under, or in connection with any matter
arising under, the internal revenue laws, of a return,
affidavit, claim, or other document, which is
fraudulent or is false as to any material matter,
whether or not such falsity or fraud is with the
knowledge or consent of the person authorized or
required to present such return, affidavit, claim, or
document;
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