- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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