Robert E. Dunham - Page 15

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          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 the             





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