- 20 -
“willfully” made and signed his 1991 and 1992 individual tax
returns that he “did not believe” [were] “true and correct” [and]
“willfully omitted true and correct information concerning” [his]
“income, knowing then that” he “had additional reportable income”
of $78,454 and $75,587 for 1991, and 1992, and that there was
additional tax due and owing on this additional income of $19,299
and $10,377 for 1991 and 1992, respectively.
J. Significant Events in Petitioner’s Life
Before and during the years at issue, petitioner encountered
a series of stressful events. These events included the
following: Two of his friends/employees died; his and his
girlfriend’s child was stillborn; his friend and financial
adviser broke his neck and became a quadriplegic; his former
brother-in-law died in a motorhome fire outside of petitioner’s
office; he was sued in connection with an accident between one of
petitioner’s trucks and a police officer; and his mother was
diagnosed with lung cancer.
OPINION
Respondent determined that during 1990, 1991, and 1992,
petitioner engaged in a scheme to divert income from his business
activities and thereby failed to report substantial earnings on
his income tax returns in order to fraudulently evade the payment
of tax. Petitioner does not dispute that he underreported
income. Petitioner’s argument centers on his state of mind and
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011