- 4 - 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;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011