Darrell L. Gaines - Page 23

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          suggests that he had little respect for Federal and State tax               
          requirements.  Furthermore, petitioner concealed these cash                 
          payments not only by his failure to file the requisite Federal              
          and State employment tax returns, but by not claiming such                  
          payments as deductible expenses on Grand Video’s Schedules C.               
          Petitioner’s willingness to give up what would otherwise be                 
          allowable deductions strongly suggests the existence of                     
          unreported cash income.                                                     
               After careful consideration, we find that respondent has               
          satisfied his burden of showing that the underpayment of tax                
          required to be shown on petitioner’s return for each year in                
          issue is due to fraud.                                                      
               Reviewed and adopted as the report of the Small Tax                    
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be                    
                                             entered for respondent.                  

















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