- 60 - 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, 105Page: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 Next
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