-9- with respondent, and they consistently provided respondent’s representatives with implausible or inconsistent explanations for their behavior. See Bradford v. Commissioner, 796 F.2d 303, 307 (9th Cir. 1986) (stating that the failure to report income, maintain adequate records, and cooperate with the Commissioner are “badges of fraud” from which fraudulent intent may be inferred), affg. T.C. Memo. 1984-601. Petitioners conducted transactions in cash during the years at issue and failed to substantiate the sources of their cash; their failure to classify their cash transactions and expenses in a manner consistent with applicable law for the taxable years at issue was fraudulent with the intent to evade tax. Accordingly, petitioner is liable for the 6651(f) addition to tax, and petitioners are both liable for the section 6663 penalty. To reflect the foregoing, An order of dismissal and decisions will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011