Terrell Equipment Company, Inc., et al. - Page 8

                                        - 8 -                                         
          had bank deposits from unexplained sources that substantially               
          exceeded reported income, concealed bank accounts, used                     
          fictitious names or names of relatives to disguise ownership of             
          assets, used a safe deposit box to hide valuables, utilized large           
          sums of currency, kept a double set of books, made fictitious               
          entries in or altered TECO’s books, created fictitious invoices             
          or other documents, concealed records, destroyed records, failed            
          to keep records, refused to make records available, asked third             
          parties to alter their records or hide their transactions with              
          petitioners, had income from illegal activities, failed to file             
          tax returns, made implausible or inconsistent explanations, or              
          attempted to hinder, delay, or interfere with the IRS’s                     
               The statutory notices of deficiency determined that the                
          deficiencies in their entirety were due to fraud.  Respondent               
          concedes that absent a finding of fraud, the periods of                     
          limitations for all the years in issue have expired.  Respondent            
          argues that the only reasonable inference that can be drawn from            
          the facts of these cases is that Vernon, Janet, and TECO                    
          fraudulently understated their taxable income for each of the               
          years in issue.  We disagree.                                               
               The addition to tax and penalty in the case of fraud is a              
          civil sanction provided primarily as a safeguard for the                    

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011