Michael London - Page 64

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             Commissioner, 89 T.C. 1280, 1302 (1987).  In addition,                   
             Mr. London supplied inaccurate information to Mr. Trugman,               
             an accountant who prepared the Schedules C for M.L.                      
             Associates.  Mr. Trugman testified that he was not able                  
             to track all the deposits made into accounts for M.L.                    
             Associates.  Providing incorrect information to a tax                    
             return preparer is also a badge of fraud.  Estate of                     
             Temple v. Commissioner, 67 T.C. 143, 162-163 (1976).                     
                  Upon consideration of the entire record, we find that               
             respondent has proven by clear and convincing evidence that              
             Mr. London acted with the requisite fraudulent intent, and               
             that the entire understatement of tax for 1983 and 1985                  
             is due to Mr. London's fraud, as determined by respondent.               
             Accordingly, we sustain respondent's determination that                  
             Mr. London is liable for the additions to tax for fraud                  
             under section 6653(b)(1) and (2).                                        
                  We reach a different conclusion with respect to                     
             Mrs. London.  In her case, we do not believe that                        
             respondent has proven by clear and convincing evidence that              
             she intended to evade tax believed to be owing by conduct                
             intended to conceal, mislead, or otherwise prevent the                   
             collection of such tax.  See Recklitis v. Commissioner,                  
             91 T.C. at 909; Rowlee v. Commissioner, 80 T.C. at 1123.                 








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