K & M La Botica Pharmacy, Incorporated, et al. - Page 39

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               Ahmed’s testimony lacked credibility and was replete with              
          inconsistencies.                                                            
               Based on Ahmed’s pattern of understating his and K & M’s               
          taxable income and of underpaying his and K & M’s Federal income            
          tax liabilities, and the conduct described above, we conclude               
          that respondent has established by clear and convincing evidence            
          that both Ahmed and K & M acted willfully and with specific                 
          intent to underpay their correct Federal income tax due for each            
          year in issue.  Ahmed and K & M have not established that any               
          portion of the tax deficiencies is not attributable to fraud.               
          Accordingly, the entire individual and corporate Federal income             
          tax deficiencies, as determined herein, are subject to the                  
          relevant fraud penalties under sections 6663(a) and 6651(f).                
               We have considered all arguments made herein, and, to the              
          extent not addressed, we conclude that they are without merit or            
          are irrelevant.                                                             
               To reflect the foregoing,                                              
                                        Decisions will be entered                     
                                   under Rule 155.                                    














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