-61-
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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