- 29 - The record here is replete with evidence of petitioners’ fraudulent intent. Petitioners, tax professionals who prepare tax returns for a living and represent clients before the Internal Revenue Service, were aware of the need for documentation and records to support the items reported on tax returns. In light of their having that knowledge, coupled with other evidence, we find that their discarding of their supporting income and client documentation was an intentional act designed to conceal and evade the reporting and payment of Federal income tax. Other factors that support a finding of fraud include the relatively large underpayments, use of the corporate entity to conceal information from creditors (including respondent), manipulation of deductions and income between the corporate and partnership entities, dealing in cash (including the purchase of multiple cashier’s checks on the same date in amounts less than $10,0006), failure to deposit and account for payments for services from clients, use of multiple bank accounts and failure to disclose their existence to respondent’s agent, failure to cooperate with respondent’s agent (including refusal to divulge the names of clients), attempts to obtain corporate deductions by making monthly payments as travel reimbursement when such travel was both undocumented and not for business purposes, and manipulation of income between petitioners and their family members. 6 Financial institutions are required to report to the Federal Government cash transactions in excess of $10,000. See 31 U.S.C. sec. 5313(a) (1994); 31 C.F.R. sec. 103.22 (1995).Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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