- 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, 105
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