Robert T. and Mary F. Gow - Page 48




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          a conclusion that they structured their dealings in WVI and                   
          Powhatan Associates in such a way as to purposely evade the payment           
          of taxes.  We disagree.                                                       
               We do not find petitioners to be tax sophisticated.  Although            
          marginally experienced in business matters, neither Dr. nor Mr. Gow           
          had substantial knowledge or training in tax law.  Dr. Gow’s                  
          advanced degrees were in the field of education, not business.                
          Before the formation of WVI, her experience and training dealt more           
          in the operational management and planning side of business than              
          with the accounting or economic side.  Several courses in tax do              
          not make one an expert.  Additionally, we draw no inferences                  
          regarding Dr. Gow’s tax sophistication from a letter she wrote to             
          her personal accountant (Mr. Bielat) regarding her entitlement to             
          specific deductions.                                                          
               Although we find petitioners’ testimony self-serving, we do              
          not necessarily find their testimony untruthful or devious.  Nor              
          are we convinced that petitioners deliberately caused their travel            
          and entertainment expenses to be hidden in the company’s books in             
          a way designed to avoid taxes.  The fact that Revenue Agent Puchaty           
          could not find the expenses in the accounts where he expected them            
          to be does not persuade us that petitioners intentionally “hid                
          them”.                                                                        
               Respondent cites Grossman v. Commissioner, T.C. Memo. 1996-              
          452, for the proposition that in circumstances similar to those               






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