-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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011