Bilsky v. Commissioner

OPINION.

Opper, Judge:

Petitioners virtually concede understatements of income in the 3 years before us averaging more than $10,000 a year.1 In addition, they had underreported their net income for the 3 preceding years. These amounts are of sufficient size to demonstrate that they could not have been unintentionally omitted, and the repetition demonstrates a pattern which in itself indicates that their omission was intentional.2 Without more, that would support an inference of willfully fraudulent conduct.

As the United States District Court said in United States v. Florida, 165 F. Supp. 328…