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summons. During the civil audit and criminal investigation,
petitioner repeatedly refused to claim certified letters sent to
her by the IRS. Petitioner explained that she refused the
letters because they were addressed to “Padgett Price Ludlow” and
not to “Padgett Price”. Petitioner’s name was listed on each of
her returns for the years in issue as “Padgett Price Ludlow”.
Petitioner also instructed her representatives to be
uncooperative. Petitioner lied to respondent’s agents and
attempted to persuade her employees to lie to the Government.
Sixth, petitioner’s pattern of conduct establishes an intent
to mislead. Apart from the conduct just previously mentioned,
petitioner apparently committed insurance fraud and a fraud on
the U.S. district court when she claimed to be indigent.
Petitioner also fabricated documents intended to be exculpatory.
Seventh, as stated supra, petitioner’s testimony totally
lacked credibility and is not worthy of belief.
Petitioner repeatedly denied ever signing a power of
attorney authorizing Mr. Gordon to represent her at the criminal
conference. After respondent obtained and submitted a copy of
this power of attorney, petitioner claimed that she forgot
signing it.
Petitioner introduced a document at trial referred to as the
“pegboard register”. This document was not produced at audit or
during discovery. The exhibit admitted was not the original, but
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