- 19 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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