Bill McDonald - Page 29

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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                 

               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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