- 22 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011