- 11 - Petitioners’ failure to provide a plausible explanation of their behavior with regard to the calculation of the figures provided to their tax preparer is indicative of fraud. See id. at 307. Petitioners represented on several loan applications with various financial institutions during the years in issue that they had vastly larger incomes than they had represented either to Greenfield in the course of his preparation of their returns for those years or to the IRS. They also provided a copy of a purported 1998 tax return to Redding Bank that showed income four times the amount that was actually reported to the IRS for 1998. Petitioners argue that the inconsistent information that they provided to financial institutions consisted of “mere estimations of their income” and thus should not be viewed as evidence of fraudulent intent to conceal income from the IRS, to which petitioners reported substantially lower incomes. However, the large discrepancies in the income that petitioners reported to the IRS and the income reported to the lending institutions, coupled with the 1998 tax return submitted to Redding Bank that was selectively altered to show four times more income to petitioners than the return that was actually filed with the IRS for 1998, are convincing evidence of petitioners’ dishonesty and of fraudulent intent to conceal income from the IRS. Petitioners have not presented any plausible explanation of these discrepancies.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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