Case: Attorney Guilty of Filing False Return, Failure to Pay as Willfulness Proven (D. Conn.) (§7206)

Evidence at trial shows pattern of underreporting income leading to a conviction for filing a false return under I.R.C. §7206, a district court held. Taxpayer, an attorney, was overdue on income tax payments. Then, during a three-year period, Taxpayer filed his returns late claiming lower gross receipts for his law practice than trust accounts deposits suggest. Taxpayer spent money building a luxury home and made other purchases, including a Ferrari, instead of paying outstanding taxes. Taxpayer argued that he lacked the intent to file a false tax return. The magnitude of Taxpayer’s underreporting, over a period of several ...