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for 1965, $241,895 for 1966, $98,213 for 1967, $221,132 for 1968,
$258,763 for 1969, and $17,945 for 1970.
b. Corporate Diversions for Personal Use
A taxpayer's diversion of corporate funds to the taxpayer's
own use is evidence of fraud. Solomon v. Commissioner, 732 F.2d
1459, 1460-1461 (6th Cir. 1984), affg. T.C. Memo. 1982-603;
United States v. Brill, 270 F.2d 525, 527 (3d Cir. 1959). As
discussed above, petitioner diverted a substantial amount of
funds from Resyn using Polymer and Chemical Traders as nominee
accounts. He diverted to Chemical Traders $297,115.19 in 1964,
$248,435.81 in 1965, $526,815.33 in 1966, $253,767.62 in 1967,
$66,554.58 in 1968, $70,878.23 in 1969, and $15,600 in 1970. He
diverted to Polymer $238,556 in 1964, $87,750.02 in 1966,
$40,517.47 in 1968, $122,649.81 in 1969, and $5,370.72 in 1970.
After petitioner diverted funds to Polymer and Chemical Traders,
he withdrew cash from the Polymer and Chemical Traders accounts,
and used the Chemical Traders account to pay for his stock
investments. In addition to the amounts petitioner diverted to
himself through Polymer and Chemical Traders, Resyn paid
substantial amounts for petitioners' personal expenses which
petitioners did not report.
c. False or Inadequate Records
False entries in books and records and false purchase
invoices are compelling evidence of fraud. Marienfeld v. United
States, 214 F.2d 632, 634-635 (8th Cir. 1954); United States v.
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