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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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Last modified: May 25, 2011