- 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
Last modified: May 25, 2011