Linda Ruth Palmer - Page 6




                                        - 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 federal               





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011