Chester H. and Michelle R. Rossman - Page 24

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          IV. Conclusion                                                              
               On the basis of the record and considering all the facts and           
          circumstances in this case, petitioner’s actions demonstrate a              
          majority of the indicia of fraud considered by this Court.                  
          Respondent has met his burden of proof by providing clear and               
          convincing evidence that petitioner not only established a                  
          pattern of failing to file income tax returns, but he also                  
          created trusts designed to conceal his income, thereby knowingly            
          attempting to evade taxes.  Thus, respondent has shown that at              
          least some portion of the underpayment for each of the years in             
          issue was due to fraud.  Moreover, petitioner did not demonstrate           
          that any portion of the underpayment was not attributable to                
          fraud.  Accordingly, the Court finds that petitioner is liable              
          for an addition to tax under section 6651(f) for 1997 through               
          2000.                                                                       
               The Court has considered all of petitioner’s contentions,              
          arguments, requests, and statements.  To the extent not discussed           
          herein, we conclude that they are meritless, moot, or irrelevant.           
               To reflect the foregoing and concessions made by respondent,           


                                                  Decision will be entered            
                                             under Rule 155.                          








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