- 27 - They did not deal primarily in cash in their personal capacity; e.g., all of the rent that they received was paid by check. They cooperated with respondent as to their audit; e.g., they promptly gave Revenue Agent Smith their amended returns reporting additional income for those years and expeditiously transferred to respondent all of the records which they maintained as to themselves individually. Although we agree with respondent that petitioners were less than upfront with the State of Michigan in 1988 as to the purchase price of the Tollycraft, and in this regard filed a false document with the State, this fact does not convince us clearly that petitioners possessed the requisite fraudulent intent for that year as to their Federal income tax liability.9 All of the parties’ arguments have been considered, and we have rejected those arguments not discussed herein as meritless. Accordingly, Decision will be entered under Rule 155. 9 Nor do we believe that some of petitioners’ explanations as to their behavior, explanations which we find implausible or inconsistent, dictate a finding of fraud in any of the years.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
Last modified: May 25, 2011