Mark N. Wright and Erica Y. Wright - Page 34

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          activities; (8) attempting to conceal illegal activities;                   
          (9) dealing in cash; (10) failing to make estimated tax payments;           
          and (11) filing false documents.  See Spies v. United States,               
          supra at 499; Bradford v. Commissioner, supra at 307-308.                   
          Additional factors to be considered include the taxpayer’s                  
          background, level of education, and prior history of filing                 
          proper returns.  Niedringhaus v. Commissioner, 99 T.C. 202, 211             
               The instant case involves many “badges” of fraud.                      
          Accordingly, the Court concludes that Mr. Wright fraudulently               
          intended to underpay taxes for 1999, 2000, and 2001.  Notably,              
          Mr. Wright is sophisticated in tax matters.  He is a certified              
          public accountant and certified financial planner, has a master’s           
          degree in business administration, and owns and operates an S               
          corporation that provides accounting services and tax advice to             
          its clients.  Additionally, Mr. Wright failed to cooperate with             
          the tax authorities.  Mr. Wright was not a credible witness as he           
          frequently gave inconsistent and implausible answers to questions           
          asked during trial.                                                         
               Specifically in 1999, Mr. Wright concealed income by                   
          transferring $54,000 to petitioners’ offshore bank account.  Mr.            
          Wright structured petitioners’ $54,000 deposit transaction                  
          specifically to avoid the exportation of monetary instruments               
          reporting requirements.  Additionally, Mr. Wright constructed a             

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