Dwight L. McKenna and Beverly S. McKenna - Page 37

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                  e.  Concealment of Income or Assets                                                   
                  The concealment of income or assets is an indicium of fraud.                          
            Bradford v. Commissioner, supra at 307-308.                                                 
                  The facts clearly show that petitioner concealed substantial                          
            amounts of income by his actions.  During the civil examination                             
            by Ms. Davis, the revenue agent, petitioner did not furnish any                             
            statements to her pertaining to his Shearson investment account                             
            until she discovered a canceled check payable to Shearson.  In                              
            addition, he never provided statements to Ms. Davis regarding his                           
            investment account at the Howard, Weil Company, despite                                     
            substantial deposits made to it.                                                            
                  Petitioner intended to conceal income by cashing some 300                             
            checks at Circle Food Store and Liberty Bank, rather than First                             
            Federal, his own bank, and then telling Mr. Bruno, his                                      
            accountant, and Ms. Davis that all income checks he received from                           
            attorneys were deposited into his First Federal checking account.                           
                  Furthermore, petitioner did not tell Mr. Bruno or Ms. Davis                           
            that he exchanged checks from attorneys for First Federal bank                              
            checks, that the exchange would not be reflected in his First                               
            Federal checking account, and that he deposited the bank checks                             
            into his investment accounts.  Without such information neither                             
            Mr. Bruno nor Ms. Davis would have known that the income existed.                           
            Thus, petitioner withheld necessary information that misled his                             
            accountant and the revenue agent.                                                           






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