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(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
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