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of income tax liability, Holland v. United States, 348 U.S. 121,
137-139 (1954); concealing income from return preparers, Korecky
v. Commissioner, 781 F.2d 1566, 1569 (11th Cir. 1986), affg. T.C.
Memo. 1985-63; diverting corporate funds to the taxpayer's
personal use, United States v. Thetford, 676 F.2d 170, 175 (5th
Cir. 1982); using a corporation to disguise the personal nature
of expenses, Truesdell v. Commissioner, 89 T.C. 1280, 1302-1303
(1987); and failing to cooperate with tax authorities, Bradford
v. Commissioner, 796 F.2d 303, 307 (9th Cir. 1986); Petzoldt v.
Commissioner, supra at 700.
The Gilchrists' conduct during the years in issue is laden
with these indicia of fraud. The Gilchrists substantially
understated their individual tax liability during the years in
issue by failing to report income diverted from Door Control.
These diversions were concealed from their return preparer. In
addition, the Gilchrists misclassified personal entertainment,
travel, and utility expenses as business expenses and used Door
Control to deduct such expenses. During the examination, Mr.
Gilchrist provided numerous false and misleading answers to
Revenue Agent Caid's questions. As a result, we conclude that
the Gilchrists intended to evade taxes.
With respect to Door Control's corporate returns, the
requisite intent to evade taxes is similarly present. A
corporation can act only through its officers and does not escape
responsibility for acts of its officers performed in that
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