Ronald B. and Annette C. Talmage - Page 84




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              On this record, petitioner’s conduct evidences an intent to             
         conceal income and assets to mislead respondent for the purpose of           
         evading tax.                                                                 
                   7.   Failure To Cooperate With Tax Authorities                     
              Petitioner was not cooperative or forthright with respondent.           
         Throughout the examination and pretrial stages of this case                  
         petitioner resisted disclosure of documentation and information              
         requested by respondent directly related to his employment and his           
         relation to his purported employer.  When responding to questions,           
         he gave contradictory and misleading answers.  On this record,               
         petitioner failed to cooperate with the tax authorities.                     
                   8. Underpayment Attributable to Fraud                              
              After consideration of all the relevant factors, the Court              
         concludes respondent proved by clear and convincing evidence that            
         petitioner’s underpayments of tax with respect to the funds wire             
         transferred to him in the years at issue were attributable to                
         fraud under section 6663(a).  Therefore, the underpayment of tax             
         attributable to the gains petitioner recognized from the sales of            
         the Vancouver and Black Butte properties are also attributable to            
         fraud unless he can establish by a preponderance of the evidence             













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