-6-
respondent, and prevent the collection of tax. Akland v.
Commissioner, 767 F.2d 618, 621 (9th Cir. 1985), affg. T.C. Memo.
1983-249; DiLeo v. Commissioner, 96 T.C. 858, 875 (1991) (holding
that a corporation may be liable for fraud if its officer has the
fraudulent intent to evade its taxes), affd. 959 F.2d 16 (2d Cir.
1992). In addition, Ms. Ngo did not cooperate with respondent
(i.e., she did not return phone calls, answer letters, or attend
scheduled meetings). Accordingly, petitioners are each liable
for the section 6663 penalty.
To reflect the foregoing,
Appropriate orders of
dismissal and decisions will be
entered for respondent.
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Last modified: May 25, 2011