Virginia Ferguson, f.k.a. Virginia Del Bosque, and Estate of Armand J. Del Bosque, Deceased, Lori Del Bosque, Special Administrator, et al. - Page 39

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          income from those returns with the intent to evade taxes.  Mr.              
          Jacobsen admitted in his plea agreement in his criminal tax                 
          proceeding that he schemed with Mr. Del Bosque to hide income and           
          evade taxes, filed false tax returns for 1987 and 1988 in                   
          furtherance of that scheme, and omitted substantial income from             
          those returns with the intent to evade taxes.                               
               For purposes of the sentencing guidelines, Mr. Del Bosque              
          stipulated that he “employed the same course of conduct and a               
          common plan with respect to the evasion of taxes in tax years               
          1987, 1988, and 1989”, and Mr. Jacobsen stipulated that he                  
          “employed the same course of conduct and a common plan with                 
          respect to the evasion of taxes in tax years 1987 and 1988”.                
          They reiterated the substance of those admissions in testimony              
          supporting their guilty pleas.                                              
               Mr. Del Bosques’s admissions are strong evidence that he               
          intended to evade taxes he knew to be owing in 1988 and 1989.               
          Mr. Jacobsen’s admissions are strong evidence that he intended to           
          evade taxes he knew to be owing in 1988.                                    
                    7.   Dishonesty in Business Transactions                          
               A taxpayer’s dishonesty in business transactions or                    
          willingness to defraud others may indicate a willingness to                 
          defraud the Commissioner.  Solomon v. Commissioner, 732 F.2d                
          1459, 1462 (6th Cir. 1984), affg. per curiam T.C. Memo. 1982-603;           
          McGee v. Commissioner, 61 T.C. 249, 260 (1973), affd. 519 F.2d              






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