Dennis E. Runkle and Debra A. Runkle - Page 26

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               5.   Failing To Cooperate With Tax Authorities                         
               We next consider petitioners’ level of cooperation with                
          respondent.  Failure to cooperate with the Internal Revenue                 
          Service (IRS) is an indicium of fraud.  Douge v. Commissioner,              
          supra; Bradford v. Commissioner, supra at 307; Recklitis v.                 
          Commissioner, supra.  Petitioners did not cooperate with                    
          respondent’s investigations.  Petitioners actively sought to                
          delay respondent’s investigation by refusing to meet with                   
          respondent’s agents or refusing to offer alternative dates on               
          which to meet.  Failing to appear at a scheduled interview caused           
          Revenue Agent Andrews to issue a summons to Mrs. Runkle to appear           
          on October 31, 1994, with her books and records.  When Mr. Runkle           
          phoned Revenue Agent Andrews to advise him that Mr. Runkle would            
          accompany his wife to the summons conference, Mr. Runkle declined           
          the revenue agent’s offer to reschedule a meeting to examine Mr.            
          Runkle’s records, a meeting that Mr. Runkle previously refused to           
               At the summons conference, Mrs. Runkle was accompanied by              
          Mr. Runkle and four other individuals who refused to identify               
          themselves.  Mrs. Runkle failed to bring any of the requested               
          books and records as summoned.  Mrs. Runkle claimed she needed              
          the personal residence address of Revenue Agent Andrews before              
          she would comply with the summons.  When the revenue agent                  
          provided his business address rather than personal address, Mrs.            

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