- 8 - 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, whichPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011