St. Luc Valbrun - Page 8

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          lost, failure to produce the available documents initially was              
          misleading and inconsistent.  We find incongruous the fact that             
          petitioner claims to have lost records pertaining to income but             
          was able to produce organized documents to substantiate expenses.           
               Petitioner’s contention that the omitted income from                   
          insurance sales should have been reported on a corporate tax                
          return is without effect because the income was not reported by             
          any entity.  Petitioner prepared over 1,500 tax returns.                    
          Petitioner’s knowledge of the tax law belies the argument that he           
          did not know the proper treatment of his income.  Even if                   
          petitioner thought the insurance income should have been reported           
          on a corporate tax return, that belief does not justify                     
          petitioner’s reporting only a portion of the insurance income on            
          his individual return and not reporting any income from other               
          businesses that were not incorporated.                                      
               Fourth, petitioner failed to cooperate with the examiner.              
          Petitioner’s failure to provide available documents relating to             
          income is a failure to cooperate.  Petitioner’s subsequent                  
          cooperation does not make up for his failure to cooperate with              
          the examiner initially.                                                     
               Fifth, petitioner’s business was conducted almost                      
          exclusively in cash.  While petitioner contends that it was                 
          customary to conduct business in cash in his native Haiti, that             
          does not justify petitioner’s Florida cash businesses, which                






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