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benefit and use of Mr. Cordes and his family. Petitioner
concedes that it omitted gross receipts in the amount of
$251,462.15 from its 1990 return, including the $127,889
with respect to which respondent determined the fraud
penalty. Respondent has also proven that the omission of
income in the amount of $127,889 was accomplished through
a scheme designed by petitioner's president, Mr. Cordes, to
divert petitioner's collection of late charges, bankruptcy
receipts, and miscellaneous other receipts to shareholder
loan account 312, and thereby to disguise the omitted
income as loans or advances from Mr. Cordes and his family.
Mr. Cordes instructed petitioner's bookkeeper to book the
subject receipts to account 312, rather than to an income
account.
Furthermore, during the audit, respondent's agent
asked Mr. Cordes for petitioner's bank records in order
to make a bank deposits analysis. Mr. Cordes refused the
agent's request and forced the agent to obtain the records
directly from the bank. Mr. Cordes' refusal to cooperate
with respondent's agent suggests that he intended to
conceal petitioner's omission of the income in account
312. Cf. Zell v. Commissioner, supra at 1146.
We reject petitioner's contention that it relied in
good faith on the professional advice of its accountants.
There is no evidence in the record that petitioner's
outside accountants were aware of the omitted receipts or
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