- 7 - Commissioner's determinations with respect to the additions to tax for fraud including: (1) Understating income, (2) maintaining inadequate records, (3) failing to cooperate with tax authorities, and (4) failing to make estimated tax payments. See Recklitis v. Commissioner, 91 T.C. 874, 910 (1988). In the instant case, the deemed admissions pursuant to Rule 37(c) include petitioners' admission to a number of indicia of fraud. Specifically, petitioners are deemed to have admitted that they: (1) Failed to file timely income tax returns for the years 1987 through 1992; (2) failed to cooperate with the revenue agent conducting the audit of their tax liability for 1987 through 1993; (3) failed to maintain and/or provide respondent with complete and accurate records concerning their income and expenses; (4) failed to provide the account numbers or bank names for all accounts that they maintained during tax years 1987 through 1993; (5) fraudulently and with the intent to evade the payment of tax understated gross receipts in the amounts of $84,245.08, $166,894.49, $230,670.52, $248,756.27, $359,718.81, $292,114.15, and $453,071.47 for tax years 1987 through 1993, respectively; (6) fraudulently and with the intent to evade the payment of tax failed to report $3,035 and $1,000 of other income received during tax years 1987 and 1992, respectively; (7) fraudulently and with intent to evade the payment of tax claimed false net operating loss carry forwards in the amounts of $19,455, $29,091, $36,439, $38,680, and $99,818 on their incomePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011