Armin Unger - Page 13




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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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