- 17 - petitioner’s 1990 return fraudulently understated petitioner’s income by $125,000.9 Based upon our examination of the entire record before us, we find that respondent has established by clear and convincing evidence that petitioner through Mr. Duncan intended to evade tax for petitioner’s taxable years 1990 and 1991, which petitioner through Mr. Duncan believed to be owing, by conduct intended to conceal, mislead, or otherwise prevent the collection of such tax. We have considered all of petitioner’s contentions, argu- ments, and requests that are not discussed herein, and we find them to be without merit and/or irrelevant. On the record before us, we shall grant respondent’s motion. To reflect the foregoing, An order granting respondent’s motion will be issued, and decision will be entered under Rule 155. 9We note that on Mar. 24, 1993, Mr. Duncan acknowledged to respondent’s revenue agents that petitioner would have to pay fraud penalties for its taxable years 1990 and 1991.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011