Roy J. Chase - Page 9

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          taxpayer’s correct liability, implausible or inconsistent                   
          explanations of behavior, concealment of assets, and failure to             
          make estimated tax payments.  See, e.g., Bradford v.                        
          Commissioner, 796 F.2d 303, 307-308 (9th Cir. 1986), affg. T.C.             
          Memo. 1984-601; Powell v. Granquist, 252 F.2d 56, 60 (9th Cir.              
          1958); Grosshandler v. Commissioner, 75 T.C. 1, 20 (1980);                  
          Gajewski v. Commissioner, 67 T.C. 181, 199 (1976), affd. without            
          published opinion 578 F.2d 1383 (8th Cir. 1978).                            
               Petitioner stipulated to the payments received from 1988               
          through 1997.  He admitted during his testimony that he received            
          funds for work performed during each of the years in issue.                 
          Proof of gross receipts is sufficient to satisfy respondent’s               
          burden of showing an underpayment for 1987 and 1988 in the                  
          absence of evidence of offsetting deductions.  See, e.g.,                   
          Greenwood v. Commissioner, T.C. Memo. 1990-362.  Petitioner has             
          neither argued nor shown that he had any offsetting deductions              
          not allowed in respondent’s determination.                                  
               In defending the charge of fraud, petitioner attempts to               
          rely on his letters openly stating his position to the IRS.                 
          Those letters, however, commenced only after his failure to                 
          comply with his obligations had been discovered.  They are not              
          persuasive evidence negating fraud.  See Rowlee v. Commissioner,            
          supra at 1124.                                                              








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