Robert E. Iles and Monica M. Iles - Page 61

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               We conclude, and we have found, that respondent has shown by           
          clear and convincing evidence that petitioners had an                       
          underpayment of tax for 1982.                                               
               (4)  Summary                                                           
               We hold that petitioners had an underpayment of tax for each           
          of the years 1980, 1981, and 1982.                                          
               We hold for respondent on this issue.                                  
          B.  Fraudulent Intent                                                       
               As Robert's own listing of his business enterprises (supra             
          table 1) suggests, and as our Findings of Fact amply confirm,               
          Robert wove a marvelously tangled web.28                                    
               Throughout the period before us Robert created and managed             
          or supervised entities designed to produce or manage cash-flows.            
          Robert saw to it that he and Monica tapped into these cash-flows            
          to satisfy their own personal standard-of-living needs, or their            
          investment or legal defense needs, without regard to whether                
          those "tap-ins" were legitimate expenditures by the entities                
          whose cash was used.  In most instances it appears that the                 
          entities did not file Federal income tax returns.  Some entities            
          were little more than misleading names on bank accounts.                    




               28   Oh, what a tangled web we weave,                                  
               When first we practice to deceive!                                     
               --Sir Walter Scott, Marmion, canto VI,                                 
                    stanza 17 (1808).                                                 




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