- 5 -
Mr. Evans had a ranching business that he operated as a
sole-proprietorship, and Ms. Evans knew about Mr. Evans'
involvement in this business. In 1989, Mr. Evans sold some of
the business' cattle, and he deposited the proceeds into the
business' bank account (the ranch account). Mr. Evans recorded
this sale in the business' sales journal, and he filed the sales
receipt with the business' records. Neither he nor Mr. Osherow
reported this sale for Federal income tax purposes.
Ms. Evans signed the tax returns at issue without reviewing
them. All of these returns were prepared by an accountant, and
Ms. Evans could have reviewed the returns before signing them.
Ms. Evans was with Mr. Evans when she signed the returns, and she
could have discussed the contents of the returns with him at or
before the time that she signed them. Ms. Evans never questioned
the contents of the returns, and Mr. Evans did not coerce her
into signing them. Mr. Evans did not exercise undue influence
over Ms. Evans with respect to their financial affairs.
The Evanses maintained records on their personal finances;
the records included journals, ledgers, bank statements,
receipts, and canceled checks. Ms. Evans received the bank
statements in the mail, and, when she did, she would place the
statements in a cabinet in the Evanses' dining room. All of the
Evanses' other records, including records on Mr. Evans' business,
were kept in an unlocked office on the second floor of their
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011