- 65 - 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 actionPage: Previous 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 Next
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