Padgett Coventry Price - Page 33

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          T.C. 874, 910 (1988).  Although no single factor is necessarily             
          sufficient to establish fraud, the combination of a number of               
          factors constitutes persuasive evidence.  Solomon v.                        
          Commissioner, 732 F.2d 1459, 1461 (6th Cir. 1984), affg. per                
          curiam T.C. Memo. 1982-603.                                                 
               The evidence establishing petitioner’s fraudulent intent is            
          overwhelming.  First, petitioner was an attorney, and she took              
          one course in taxation during law school.                                   
               Second, petitioner consistently and substantially                      
          understated her income.  This is strong evidence of fraud when              
          coupled with other circumstances.  Marcus v. Commissioner, 70               
          T.C. 562, 577 (1978), affd. without published opinion 621 F.2d              
          439 (5th Cir. 1980).  A pattern of consistent underreporting of             
          income, when accompanied by other circumstances indicating an               
          intent to conceal income, may justify the inference of fraud.               
          Holland v. United States, 348 U.S. 121, 139 (1954).                         
               Third, petitioner’s explanations were implausible and                  
          inconsistent.  She kept changing her story to fit the                       
          circumstances she was faced with.  As the agents, and the Court,            
          learned the truth, petitioner would change her story.                       
               Fourth, petitioner attempted to conceal her true income by             
          depositing it into her Merrill Lynch account.                               
               Fifth, petitioner failed to cooperate with tax authorities.            
          She attempted to prevent Merrill Lynch from complying with a                






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