- 18 - provided on which estimates of additional business expenses could be made. Petitioners’ claim that the large personal investments and purchases were made with accumulated, nontaxable capital savings from earlier years is completely unsubstantiated and incredible. Petitioners’ investments in the bearer bonds and other large personal expenses that were incurred during the years in issue appear clearly to have been paid with payments from unreported sales of Cal Ben deposited into the Lloyds/Sanwa account. Instead of presenting credible evidence (e.g., receipts, invoices, and testimony of payees identified on checks representing alleged additional business expenses), petitioners largely offered only speculative testimony and general survey data. The credible evidence before us establishes that petitioner's 50-percent share of the cumulative unreported gross sales of Cal Ben is approximately $960,000. See chart supra p. 7. It is established that substantial underpayments of petitioners' correct Federal income tax liabilities occurred for each year in issue. Because of his criminal conviction for tax evasion, petitioner's fraudulent intent with regard to his 1986 Federal income tax liability is established. DiLeo v. Commissioner, 96 T.C. at 885-886; Amos v. Commissioner, 43 T.C. 50 (1964), affd. 360 F.2d 358 (4th Cir. 1965).Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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