- 7 - income tax return, which year is not before the Court in this case. (aj) The petitioner's four-year pattern of substantially underreporting income from her business evidences her intent to evade or defeat the assessment and payment of income taxes for each of those years. (ak) The petitioner's failure to reflect her operation of any business interest whatsoever on her 1982 federal income tax return, while in reality realizing net income in excess of $95,000 from the operation of that business during that year provides further evidence of her intent to defraud. (al) The petitioner's act of reporting net losses from the operation of her business on her joint federal income tax returns for each of the taxable years 1983 and 1984 while in reality realizing net income in excess of $138,000 and $103,000 during those years, respectively, provides additional evidence of the petitioner's intent to defraud. (am) The petitioner and Wayne E. Palmer enjoyed a tremendous increase in their net worth during the years here at issue while reporting negative net income on the joint tax returns which they filed with the respondent and while paying $0 in federal income tax during that same 3-year period. (an) During 1995, the petitioner entered a plea of guilty before the United States District Court for the District of Utah to wilfully [sic] filing a false federal income tax return for the 1984 taxable year in violation of 26 U.S.C. 7206(1). (ao) The material falsity to which the petitioner entered a plea of guilty was her willful failure to accurately report the true income received from her business during the 1984 taxable year. (ap) The petitioner is collaterally estopped in the instant proceeding from denying that she willfully failed to report a material amount of income from her business on her 1984 joint federal income tax return.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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