Michael London - Page 65

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             Respondent's proof of Mrs. London's fraud is principally                 
             based on the contention that she "was deeply involved in                 
             the couple's business and financial affairs."  We agree                  
             that Mrs. London owned stock in London Cafe, Inc., wrote                 
             checks on various accounts maintained by petitioners,                    
             and purchased assets such as real estate and automobiles.                
             However, there is no evidence of her involvement in                      
             Mr. London's illegal activities, the source of the                       
             unreported income.  For example, during the surveillance                 
             of Heller's Cafe, Mrs. London was never observed in the                  
             bar.  She was not a target of the Government's                           
             investigation.  As to the unreported income, Mr. London                  
             insulated his wife from the reporting of that income by                  
             supplying information for preparation of the Schedules                   
             C, Profit or (Loss) From Business or Profession, to                      
             Mr. Trugman.  The Schedules C were then given to                         
             Mr. Silverstein for preparation of petitioners' joint                    
             individual income tax returns.  There is no evidence that                
             Mrs. London was involved in the accounting for or reporting              
             of, income from Mr. London's illegal activities.  Upon                   
             consideration of the entire record, we find no clear and                 
             convincing evidence that Mrs. London took any action                     










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