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hid assets in his mother’s name, lied to respondent’s agents
about the source of his income, and consistently failed to file
income tax returns. This pattern constitutes clear and
convincing evidence that petitioner’s understatement of tax for
1988 was also due to fraud.
We hold that petitioner is liable for the additions to tax
for fraud for 1987, 1988, 1989, and 1990 as determined in the
notice of deficiency.
Decision will be entered
for respondent.
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