- 303 -
and experience are relevant. See Scallen v. Commissioner, supra
at 1371; United States v. Stein, 437 F.2d 775 (7th Cir. 1971).
1. Lisle's Fraud
Respondent has proven by clear and convincing evidence that
Lisle underpaid his taxes for each of the years at issue
attributable to omitted income from transactions related to the
Five.
Respondent has also proven by clear and convincing evidence
that Lisle intended to evade taxes known to be owing on that
income by conduct designed to conceal, mislead, or otherwise
prevent the collection of such taxes. The record contains
several indicia of Lisle's fraud with intent to evade tax.
In determining the presence or absence of fraud, we consider
the training and experience of the taxpayer. See Iley v.
Commissioner, 19 T.C. 631, 635 (1952). Lisle graduated from the
University of Missouri with a B.S. degree in public
administration. He attended law school at the University of
Missouri, graduate schools of management and business at Columbia
University, and the graduate school of management at Princeton
University. Lisle was an experienced and sophisticated
businessman who held high executive positions at Prudential and
later at Travelers. As such, he obviously understood and fully
appreciated his obligation to report income correctly and to pay
taxes on that income. Nevertheless, he disregarded this
Page: Previous 293 294 295 296 297 298 299 300 301 302 303 304 305 306 307 308 309 310 311 312 NextLast modified: May 25, 2011