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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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