Hector Prowse - Page 21

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          121, 137 (1954)); Camien v. Commissioner, 420 F.2d 283, 287 (8th            
          Cir. 1970), affg. T.C. Memo. 1968-12.                                       
               Respondent contends that the following badges of fraud exist           
          in this case:  (1) Inadequate records; (2) implausible or                   
          inconsistent explanations; (3) a pattern of behavior indicating             
          an intent to mislead; and (4) filing false documents.  On brief,            
          petitioner presented frivolous and irrelevant arguments as to the           
          credibility of the various witnesses, ignoring the documentation            
          and receipts at issue.  The Court agrees with respondent.                   
               The record establishes without a doubt that petitioner                 
          maintained and presented inadequate and false records with                  
          respect to the deductions claimed on his 2002 and 2003 returns.             
          Respondent clearly and convincingly showed, through the use of              
          credible witnesses, that a substantial number of documents                  
          attached to petitioner’s 2002 and 2003 returns in an effort to              
          establish the propriety of his deductions for both years were               
          forged or falsified.  Moreover, the documents presented for this            
          case are strikingly similar to those submitted to substantiate              
          petitioner’s claimed 2001 deductions in Prowse v. Commissioner,             
          T.C. Memo. 2006-120, and which the Court likewise found were                
          altered.  Several professionals, such as doctors, testified at              
          trial that, while they had provided services to petitioner in               
          prior years, they had not provided services to petitioner as                
          purportedly claimed on the receipts that were submitted to the              






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