- 6 - (ab) The petitioner reported none of the interest income reflected in subparagraph 6.(aa) above on her respective 1982, 1983, and 1984 federal income tax returns. (ac) In addition to the interest and business income reflected above, the petitioner realized income from the sale of a tractor during the 1984 taxable year in the amount of $4,478, which income the petitioner failed to report on her joint 1984 federal income tax return. (ad) The petitioner also received taxable social security income during 1984 in the amounts of $4,478 which she failed to report on her joint 1984 federal income tax return. (ae) The petitioner's failure to report income as reflected above on her 1982, 1983, and 1984 joint federal income tax returns was fraudulent with the intent to evade income tax. (af) The petitioner represented to third-parties that her gross, net, and taxable income from her business and from other sources was significantly higher than the income which she reported on her joint 1982, 1983, and 1984 federal income tax returns. These wilful misrepresentations included the petitioner's sworn written statements which she submitted with applications for loans. (ag) The misrepresentations reflected in subparagraph 6.(af) above indicate the petitioner's contemporaneous knowledge that her income was significantly greater than that which she reported on the tax returns which she filed with the respondent, that those returns were false, and that at all relevant times she possessed a fraudulent intent to evade the assessment and payment of income tax. (ah) The petitioner affirmatively attempted to mislead agents of the Internal Revenue Service as to her gross income for each of the years here at issue, and failed to cooperate during the respondent's examination of her true income with respect to those years. This behavior and lack of cooperation provide evidence of petitioner's intent to defraud. (ai) The petitioner also failed to report substantial income from her business on her 1985 federalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011