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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).
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