Linda Ruth Palmer - Page 7




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               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.                  







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