Michael London - Page 62

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                  Mr. London concedes that his guilty plea to tax                     
             evasion in violation of section 7201 for 1985 estops him                 
             from denying liability for additions to tax for fraud under              
             section 6653(b)(1) and (b)(2) for that year.  The issues                 
             remaining for decision are whether Mr. London is liable for              
             the additions to tax for fraud for petitioners' 1983 return              
             and whether Mrs. London is liable for the additions to tax               
             for fraud for 1983 and 1985.                                             
                  Respondent contends that the following facts, when                  
             taken as a whole, establish that petitioners' underpayment               
             of tax for 1983 and 1985 was attributable to fraud:  (1)                 
             There is a large discrepancy between petitioners' actual                 
             income and the income reported on their returns for 1983                 
             and 1985; (2) petitioners did not keep adequate books or                 
             records from which their tax liability could be computed;                
             (3) Mr. London was engaged in illegal activities;                        
             (4) Mr. London attempted to conceal his illegal activities;              
             (5) Mrs. London was actively involved in petitioners'                    
             finances; (6) Mr. London did not supply complete                         
             information about the check-cashing business' income                     
             and expenses to Mr. Trugman, the accountant who prepared                 
             the Schedule C for M.L. Associates; and (7) Mrs. London's                










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