Chester H. and Michelle R. Rossman - Page 19

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               Petitioner admitted that he knew he had a Federal income tax           
          “liability or a responsibility” to file a Federal income tax                
          “return or a statement”.  By his own testimony, petitioner                  
          purported to advise people on timely filing returns and timely              
          paying taxes.  Thus, petitioner should have been and was aware of           
          his obligations to file a tax return and pay taxes timely.                  
          Petitioner’s actions over several years established a pattern of            
          failing to file returns.  Petitioner’s reasons for failing to               
          file do not constitute mere negligence; rather, they are an                 
          indicator of intentional effort to delay payment of the income              
          tax due.                                                                    
                    4. Giving Implausible or Inconsistent Explanations of             
          Behavior                                                                    
               Petitioner testified that he was an advocate for the IRS in            
          his consulting business encouraging seminar participants to                 
          timely file their tax returns.  Yet, petitioner did not file his            
          returns or pay his taxes timely.  Petitioner’s claimed position             
          concerning the IRS and the filing and the payment of taxes is               
          inconsistent with his behavior during the 1994 through 2000                 
          taxable years.  Furthermore, petitioner’s explanation that he was           
          waiting for resolution on his 1994 through 1996 tax returns in              
          order to file tax returns for 1997 through 2000 is not                      
          persuasive, given his business background and his familiarity               
          with the timely filing requirement.                                         






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