- 47 - Despite his business acumen, petitioner failed to report his receipt of substantial amounts of income on his 1982, 1983 and 1984 returns. Hughes v. Commissioner, T.C. Memo. 1994-139; LiButti v. Commissioner, T.C. Memo. 1985-314. A taxpayer's use of cash to conceal income is evidence of fraud. Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th Cir. 1986), affg. T.C. Memo. 1984-601; United States v. Chapman, 168 F.2d 997, 1000 (7th Cir. 1948). Petitioner's method of paying the laborers in cash, and cashing their checks in larger amounts for himself without a valid business reason, is strong evidence of fraud. Petitioner attempted to conceal the receipt of substantial amounts of income from the partnerships and Newtowne by entering into a series of transactions that camouflaged receipt of these funds. For example, petitioner asked Newtowne to endorse the partnership checks to petitioner in "partial payment for his consulting services", even though it was understood between the parties that no such services would be provided. Petitioner also caused the partnerships to pay him in accordance with the respective financial consulting agreements.9 9 We note that, despite these agreements, petitioner argued in his petition that these payments from the partnerships and (continued...)Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
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