- 15 - Commissioner, 91 T.C. 874, 910 (1988). This list is nonexclusive. Miller v. Commissioner, 94 T.C. 316, 334 (1990). During the years in issue, petitioner failed to file valid tax returns and failed to report substantial amounts of income from his veterinary practice. Petitioner intentionally did not maintain records of his income or business expenses and intentionally discarded the minimal records that he received. The $65,000 amount, although stipulated in this case, cannot be shown to be the actual amount of income earned in petitioner's veterinary practice. Moreover, petitioner did not cooperate with respondent during the administrative or judicial phases of this case. Petitioner refused to meet with respondent's agent and responded to requests for meetings with tax protester rhetoric. Petitioner submitted numerous correspondence to respondent that attempted to advance his tax protester position and did not address the factual accuracy of respondent's determination. During testimony at trial, petitioner admitted that he was aware that the Tax Court has held the tax protester arguments to be frivolous. Petitioner took affirmative steps to conceal his income and assets. From 1987 until 1991, petitioner substantially avoided use of commercial banks for depositing income and paying expenses from his veterinary practice. Petitioner dealt extensively in cash for payment of expenses and did not retain receipts of thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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