- 30 - Petitioner’s explanations of her behavior were implausible and/or inconsistent. She testified that she lacked any financial or tax expertise whatsoever. We find that she has possessed both types of expertise since at least 1991. Two of her attorneys even testified to that effect. Beaudry testified that petitioner was very competent in financial matters and was intimately involved in the bankruptcy scheme and her plan to evade taxes. Jonathan A. Brod, another of her attorneys whom she called to testify, described petitioner as someone who thought she was financially astute and knowledgeable in tax matters. He testified that she asked him an average of 60 questions a week during the time that he represented her. This factor weighs against petitioner. 5. Concealing Assets Concealing assets is indicative of fraud. Id. Petitioner purposely undertook efforts to conceal her assets, and she purposely established the elaborate bankruptcy scheme to conceal her ultimate receipt of the income from the dermatology practice. In fact, the bankruptcy scheme continued to evolve over the years in both complexity and sophistication as petitioner asked her attorneys to hide more of her income. What was originally conceived as an attempt to defraud her creditors in bankruptcy evolved into a series of international transactions whereby petitioner attempted to avoid paying Federal taxesPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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