168 Garment, Inc. et al. - Page 6

                                         -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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