-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).Page: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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