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States, 317 U.S. 492, 499 (1943). Indicia of fraud may include
understated or unreported income, intentional concealment of
income and assets, and failure to cooperate with taxing
authorities. See Bradford v. Commissioner, 796 F.2d 303 (9th
Cir. 1986), affg. T.C. Memo. 1984-601. Here, petitioner
defrauded an insurance company, lied to respondent by attempting
to conceal his illegal acts and income, and intentionally failed
to report said income.
Based on the above, we hold that petitioner is liable for
the addition to tax for fraud for the 1993 taxable year. With
respect to all other matters determined, respondent does not bear
the burden of proof, and petitioner is found to have failed
properly to prosecute and defaulted on his opportunity to show
respondent’s error(s).
To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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