Chester H. and Michelle R. Rossman - Page 21

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                    5. Concealing Assets                                              
               For the taxable years 1994 through 1996, petitioner took               
          affirmative steps to conceal his assets and income, forcing                 
          respondent to serve summonses on banks and mortgage companies,              
          to use Bureau of Labor Statistics information, and to implement             
          a bank deposits analysis in order to discover bank accounts,                
          recreate petitioner’s income, and eventually determine                      
          understatements of income.                                                  
               For taxable years 1997 through 2000, petitioner continued to           
          conduct business in the name of DSG.  By not correctly reporting            
          the income earned by DSG, a disregarded trust, either on DSG’s              
          own return or on petitioner’s Form 1040, and continuing to                  
          operate under DSG, there is a strong inference that petitioner              
          did so with the intent to conceal his income.                               
                    6. Failing To Cooperate With Tax Authorities                      
               Petitioner did not cooperate with Agent Riley’s attempts to            
          obtain tax returns or financial information for the years in                
          issue.  On December 2, 2002, petitioner informed Agent Riley that           
          returns were being prepared, when, in fact, they were not.  When            
          respondent issued a notice of deficiency on August 21, 2003,                
          petitioner had still not filed the relevant tax returns.  He                
          appeared to have eventually submitted Forms 1040 only to obtain             
          deductions to decrease the deficiencies owed.                               






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