Robert M. Temple - Page 28




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               Wendy Arbogast was one of petitioner’s clients.  Ms.                   
          Arbogast testified that she had purchased a bird from petitioner            
          for $1,400 but paid $800 of the purchase price in cash.  Ms.                
          Arbogast testified that petitioner told her when she started                
          going to him for veterinary services that he preferred cash                 
          payments.                                                                   
                    3.  Use of Nominee Accounts                                       
               Use of nominees to conceal assets that a taxpayer has                  
          unfettered control over is evidence of fraud.  See Friedman v.              
          Commissioner, T.C. Memo. 1968-145, affd. 421 F.2d 658 (6th Cir.             
          1970).                                                                      
               Petitioner received checks from various customers for                  
          providing veterinarian services, the sale of animals, and                   
          royalties and deposited them into various bank accounts fashioned           
          as trustee accounts.  These deposits were derived from income               
          earned by and taxable to petitioner.  The accounts were fashioned           
          as trust accounts in an effort by petitioner to disguise the true           
          ownership of the accounts.                                                  
                    4.  Failure To Cooperate With Revenue Agents                      
               Failure to cooperate with revenue agents during the audit              
          phase of a case is an additional indication of guilty knowledge             
          on a taxpayer’s part.  See Professional Servs. v. Commissioner,             
          79 T.C. 888, 933 (1982).                                                    








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