-16-
income using the name Ray Vogt Enterprises. He failed to
cooperate with taxing authorities, including in the conduct of
this proceeding. He gave false information to taxing authorities
stating that he owned no partnership interests or rental property
during the years at issue. He refused to provide answers, or
gave evasive and irrelevant answers citing frivolous arguments on
numerous occasions. He attempted to prevent a financial
institution from complying with a notice of summons sent to it.
He filed two false Forms W-4, stating that he was exempt from
withholding taxes. Lastly, he had significant cash deposits for
the years at issue. For these reasons, we hold that petitioner
is liable for a penalty under section 6663 with respect to the
portion of the underpayment attributable to unreported income of
$19,916 for the year 2001.
2002
Respondent determined that petitioner is liable for a fraud
penalty under section 6663 for 2002. It was deemed admitted
under Rule 37(c) that petitioner fraudulently, intentionally,
knowingly, and willfully understated his taxable income by
$14,142 for the year 2002.15 In addition to the badges of fraud
listed for the year 2001, which are equally applicable to the
year 2002, petitioner used the name Springboard Ltd. Trust to
15Respondent alleged in his amended answer that petitioner
received additional amounts of unreported income, but he conceded
those amounts on brief.
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