- 47 - Petitioner submitted to banks and other businesses and governmental entities false copies of his income tax returns and false financial and other information. For 1988, petitioner reported gross receipts of $189,788, disregarding a Form 1099 from 2618 Inc reflecting nonemployee compensation to petitioner of $281,176. We are not persuaded by petitioner's arguments that he innocently and inattentively bungled his tax affairs. In light of the evidence, we view petitioner's assertions of ignorance and unsophistication as simply another attempt by petitioner to obscure the facts. For 1987 and 1988, we conclude that the increases to petitioner's taxable income that we have sustained herein (relating to bank deposits, disputed checks not deposited into petitioner's bank accounts, cash withdrawals from the Club, and deductions that we have not allowed) are attributable to fraud. For 1988, we note that the increase to petitioner's taxable income relating to petitioner's receipt of the stock of 2618 Inc is also attributable to fraud. We view petitioner's failure to report any amount as income in connection with his receipt of the stock as part of petitioner's fraudulent conduct. We recognize the difficulties in valuing the stock. Our valuation, however, is supported by petitioner's representations as to the value of 2618 Inc and by the outstanding legal fees in excess of $500,000 for which thePage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
Last modified: May 25, 2011