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Sylvia cash or by placing assets in their names. That conduct is
evidence of fraudulent intent.
(6) Failure To Cooperate with Respondent
Respondent asserts that petitioners failed to cooperate with
respondent’s agents during the examination of their returns.
Respondent maintains that petitioners’ justification for their
lack of cooperation (i.e., that in 1990 or 1991 respondent’s
revenue agent referred to all Gypsies as crooks), does not
provide a basis for failing to cooperate.
Petitioners, however, maintain that respondent is attempting
to attribute the actions of Larry and Baptiste to Frank and
Katherine. They contend that there is no evidence that Frank and
Katherine failed to cooperate with respondent’s agents during the
course of the examination of their returns, or that Katherine
made false or misleading statements to respondent’s revenue
agents. Petitioners maintain that the only employee of
respondent who requested records from Frank and Katherine was
Revenue Officer Budde, and that request related to a delinquent
filing investigation of their 1986 through 1988 returns.
Petitioners contend that Frank and Katherine cooperated with
Revenue Officer Budde by filing returns for those years even
though they were not required to file them because of the income
threshold requirements.
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