- 26 - 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 attend. 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.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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