- 275 - issue, particularly during the years for which respondent determined fraud. For example, travel and entertainment expenses were overstated by $19,913.37 in 1973, $75,284.40 in 1974, $77,315.01 in 1975, and $20,000 in 1976. In addition, for some of the years there were overstatements of some commission expenses, consulting fees, legal and professional fees, salaries and wages, interest expenses, depreciation, and rental expenses. 4. Failure to Maintain Adequate Books and Records Failure to maintain adequate books and records of income generally and failure to keep records of income diverted and unreported are both indicative of fraud. Truesdell v. Commissioner, 89 T.C. 1280, 1302 (1987); Gajewski v. Commissioner, 67 T.C. at 200. The record contains evidence showing that petitioner's books and records with respect to income and expenses were inadequate, incomplete, and sometimes misleading. Substantial income was unreported and claimed expenses were overstated or not substantiated. 5. Concealment of Income or Assets The concealment of income or assets is an indicium of fraud. Bradford v. Commissioner, 796 F.2d at 307-308. Petitioner handled the transactions involving Lockheed and Ashland to conceal from respondent the large sums of money paidPage: Previous 265 266 267 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 Next
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