K & M La Botica Pharmacy, Incorporated, et al. - Page 36

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               (1) Understatement of income;                                          
               (2) inadequate records;                                                
               (3) failure to file tax returns;                                       
               (4) implausible or inconsistent explanations of behavior;              
               (5) concealing assets;                                                 
               (6) failure to cooperate with tax authorities;                         
               (7) engaging in illegal activities; and                                
               (8) dealing in large amounts of cash.                                  

          See Edelson v. Commissioner, 829 F.2d 828, 832 (9th Cir. 1987);             
          Bradford v. Commissioner, supra at 307-308; Baker v.                        
          Commissioner, T.C. Memo. 1991-340, affd. without published                  
          opinion 9 F.3d 1550 (9th Cir. 1993).                                        
               While the underreporting of income itself may be                       
          insufficient to support a finding of fraud, “repeated                       
          understatements in successive years when coupled with other                 
          circumstances showing an intent to conceal or misstate taxable              
          income present a basis on which the Tax Court may properly infer            
          fraud.”  Furnish v. Commissioner, 262 F.2d 727, 728 (9th Cir.               
          1958), affg. in part and remanding in part 29 T.C. 279 (1957).              
          Consistent, substantial understatements of income for several               
          years is highly persuasive evidence of intent to defraud the                
          Government.  Powell v. Granquist, supra at 60.                              
               If respondent establishes that any portion of an                       
          underpayment is attributable to fraud, the entire underpayment is           





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