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7206(1) and 7203, respectively. Ms. Drummond failed to make
required estimated tax payments for 1984. She also failed to
appear at trial, which we believe was a deliberate effort by her
to conceal the facts concerning her tax liability for the years
at issue.
Mr. Drummond, a college graduate and a certified public
accountant, has knowledge of tax matters and was capable of
correctly preparing and filing his tax returns for 1983 and 1984.
He nonetheless substantially understated his income in each of
those returns. Mr. Drummond gave false, misleading, inconsis-
tent, and implausible explanations of his behavior to respon-
dent's agents during their examination of his taxable years 1983
and 1984 and thereby did not cooperate with those agents. Mr.
Drummond willfully subscribed to and filed a false tax return for
each of the years at issue, for which he was convicted under
section 7206(1). He also failed to appear at trial, which we
believe was a deliberate effort by him to conceal the facts
concerning his tax liability for the years at issue.
Based on our examination of the entire record in these
cases, we find that respondent has established by clear and
convincing evidence that each petitioner intended to evade taxes
for each of the years 1983 and 1984, which each petitioner
believed to be owing, by conduct intended to conceal, mislead, or
otherwise prevent the collection of such taxes. We further find
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