Ella Freidus - Page 22

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          secretary, Annette Pores, or petitioner's caretaker, Johnny                  
          Mongkauw, to fetch relevant records.  Furthermore, petitioner has            
          not presented evidence that Mr. Freidus' behavior prevented                  
          petitioner from requesting extensions to file her tax returns.               
          Since petitioner knew that she had the right to file requests for            
          extensions to file her returns, she must have deliberately chosen            
          not to request the extensions.  Therefore, petitioner has failed             
          to establish that Mr. Freidus prevented her from timely filing               
          her tax returns.                                                             
               The failure to make estimated tax payments supports a                   
          finding of fraud.  See Bradford v. Commissioner, 796 F.2d at 308.            
          Petitioner deliberately and consistently failed to pay estimated             
          taxes for all 4 years in issue as evidenced by the fact that                 
          petitioner was fully aware of her obligation to estimate her tax             
          liability and make estimated tax payments.                                   
               Concealing assets coupled with a failure to file tax returns            
          is a strong indication of fraud.  Using her secret Pierpont                  
          Account, accounts of third parties, and nominee corporations,                
          petitioner employed a strategy designed to conceal assets from               
          potential creditors, including respondent.  Assets in the                    
          Pierpont Account consisted mainly of proceeds from petitioner's              
          income-producing activities.  The record shows that petitioner               
          arranged to have the sale proceeds from the Golden Maharajah                 
          diamond and Picasso ceramics wired into the Pierpont Accounts.               

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