George Maciel - Page 20

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          “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             






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