Roy J. Chase - Page 11

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          Sloan, 939 F.2d 499 (7th Cir. 1991); United States v. Collins,              
          920 F.2d 619 (10th Cir. 1990); United States v. Ward, supra;                
          United States v. Schiff, 801 F.2d 108 (2d Cir. 1986); United                
          States v. Karlin, 785 F.2d 90 (3d Cir. 1986); United States v.              
          Bressler, 772 F.2d 287 (7th Cir. 1985); United States v. Romero,            
          640 F.2d 1014 (9th Cir. 1981); United States v. Buras, 633 F.2d             
          1356 (9th Cir. 1980).                                                       
               When, as here, accompanied by evidence of intent to conceal            
          income and assets, the longtime pattern of failing to file tax              
          returns is sufficient to sustain the civil penalties.  See, e.g.,           
          Niedringhaus v. Commissioner, supra at 212-213; Rowlee v.                   
          Commissioner, supra; Marsh v. Commissioner, T.C. Memo. 2000-11,             
          affd. 23 Fed. Appx. 874 (9th Cir. 2002); Houser v. Commissioner,            
          T.C. Memo. 2000-111; Harrell v. Commissioner, T.C. Memo.                    
          1998-207, affd. without published opinion 191 F.3d 456 (7th Cir.            
          1999); Dunham v. Commissioner, T.C. Memo. 1998-52.  The penalties           
          for fraud in this case will be sustained.                                   
               As indicated above, our conclusion that petitioner’s                   
          underpayment of taxes and failure to file returns was due to                
          fraud is based on the objective facts and rejection of his claims           
          of good faith.  Our reasoning is supported in part by his refusal           
          to acknowledge that his positions are contrary to law, as he was            
          advised by the IRS, relevant authorities, and the Court in this             
          case.  Petitioner persists in his frivolous and groundless                  






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