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became involved in what he considers “mainstream” tax planning
and promoted the sale of income and estate tax planning programs
using partnerships, wills, living trust, and other legal
instruments. As further evidence of Mr. Runkle’s financial
expertise, Mr. Runkle also formed DR Financial, Inc. to promote
the sale of insurance and annuities and served on a church’s
financial commission. In addition, Mrs. Runkle successfully
operated the Canyon Kennel as a sole proprietorship for many
years.
A taxpayer’s filing of income tax returns in prior years is
evidence that the taxpayer was aware of his or her obligation to
file returns. Petzoldt v. Commissioner, 92 T.C. 661 (1989); see
also Stalker v. Commissioner, T.C. Memo. 1981-544. Petitioners
had a history of consistently filing income tax returns and
paying the tax liability before the years in issue. The last
year for which they filed a return, 1990, petitioners had a
Federal tax liability of $13,467, which they timely paid with
funds borrowed from Garrett State Bank. Thereafter, petitioners
embarked on a course to avoid disclosing and paying their Federal
tax liability. This occurred after petitioners attended a
seminar in Cancun, Mexico, and bought the “untaxing” propaganda
of the American Institute that established petitioners’ “firm
belief” there was no requirement to file returns.
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