Darlow T. Madge - Page 4




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          Petitioner maintained at various locations various bank accounts            
          into which his business receipts were deposited.  Some of the               
          accounts were maintained at banks in communities distant from               
          petitioner’s residence.  Petitioner used false Federal                      
          identification numbers on some of those bank accounts.                      
          Petitioner did not file income tax returns for any of the years             
          in issue because he decided that the moneys that he received were           
          not gross income as defined by the applicable statutes and                  
          regulations.  In April 1992, petitioner purported to revoke his             
          Social Security number.                                                     
               On or about September 27, 1989, petitioner completed a                 
          residential loan application.  On that application, he                      
          represented that his employer was Allied, that he had been                  
          employed on that job for 10 years, and that his base employment             
          income was $15,000 per month.  On or about May 6, 1993,                     
          petitioner executed a uniform residential loan application on               
          which he represented that his employer was Allied, that he had              
          been 14 years on the job, and that his base employment income was           
          $20,000 per month.                                                          
               In approximately January 1994, the IRS commenced an                    
          investigation of petitioner.  Petitioner did not cooperate with             
          the investigation and, instead, sought to obstruct the                      
          investigation.  In March 1994, IRS officers and other law                   
          enforcement officials executed a search warrant at petitioner’s             






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