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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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