Leo N. Levitt and Ruth G. Levitt - Page 60

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          Lange, 161 F.2d 699, 703 (7th Cir. 1947).  Petitioner caused                
          Polymer to issue false purchase invoices to Resyn.                          
               A taxpayer's failure to maintain accurate records may be a             
          badge of fraud.  Merritt v. Commissioner, 301 F.2d 484, 487 (5th            
          Cir. 1962), affg. T.C. Memo. 1959-172; Reaves v. Commissioner,              
          295 F.2d 336, 338 (5th Cir. 1961), affg. 31 T.C. 690 (1958);                
          Grosshandler v. Commissioner, 75 T.C. 1, 20 (1980).  Petitioner             
          did not have records showing what he did with most of the money             
          in the Polymer and Chemical Traders accounts.                               
                    d.   Dealing in Large Amounts of Cash                             
               A taxpayer's use of cash and cashier's checks to conceal               
          income is evidence of fraud.  Bradford v. Commissioner, supra at            
          308; United States v. Chapman, 168 F.2d 997, 1000 (7th Cir.                 
          1948).  We may infer that a taxpayer's excessive use of checks              
          drawn to cash was to conceal unreported income.  See Gariepy v.             
          United States, 189 F.2d 459, 463 (6th Cir. 1951).  Petitioner               
          used large cash transactions.  He used cashier's checks to buy              
          stock.  All of his Polymer withdrawals were in cash.  He wrote              
          Chemical Traders checks to cash totaling $160,824 in 1965,                  
          $160,541 in 1966, $317,000 in 1967, $89,500 in 1968, $43,850 in             
          1969, and $19,500 in 1970.  There do not appear to be any valid             
          business reasons for these large cash transactions.                         
                    e.   Using Fictitious Names                                       
               Use of a bank account in the name of a nominee can be                  
          evidence of fraud.  United States v. Ratner, 464 F.2d 101, 105              




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