Ella Freidus - Page 26

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          harbor proceeds from income producing activities.  As noted                  
          above, petitioner partially repaid loans from Sotheby's with                 
          substantial amounts disbursed from the Ivory Land account.                   
          Petitioner also used funds from the Ivory Land account to buy                
          various art pieces from Christie's.  Like the Pierpont Account,              
          we think petitioner used her corporate nominees to conceal                   
               Further evidence of asset concealment is the fact that                  
          petitioner deposited proceeds from horse sales into an account               
          belonging to petitioner's broker and trainer, Margie Goldstein,              
          once again making it difficult for respondent to trace these                 
          proceeds to petitioner.                                                      
               Petitioner argues that her entire course of conduct fails to            
          demonstrate that the deficiencies were due to an intent to evade             
          taxes, citing Stoltzfus v. United States, 398 F.2d 1002 (3d Cir.             
          1968), and Nelon v. Commissioner, T.C. Memo. 1997-49, for                    
          support.  Instead of supporting petitioner's position, Stoltzfus             
          v. United States, supra, reinforces respondent's position.  In               
          that case, the Court affirmed the judgment of the District Court             
          denying the taxpayer's request for a refund of civil fraud                   
          penalties imposed pursuant to section 6653(b) of the 1954 Code.              
          The taxpayer had failed to file returns from 1943 through 1958.              
          Like petitioner, the taxpayer had extensive business experience,             
          a keen awareness of financial matters and was aware of his duty              

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