Lucio Ambroselli - Page 6




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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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