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reviewed any daily sheets, yet K.C. Urbon gave the sauna expense
records to petitioner-wife. Petitioners contend that petitioner-
wife was too sick to run the business and that she did not visit
the saunas after 1982. However, the masseuses testified that
petitioner-wife visited the saunas after 1982. Petitioners'
claim that $400,000 of their cash on hand on December 31, 1982,
came from Wilma MacFarland, Tobey Peacock, and MacFarland is
implausible.
Petitioner-wife admitted that she lied to U.S. immigration
officials so her relatives could enter the United States.
Petitioner-husband testified that he made money in Vietnam on the
black market and by skimming cash from slot machines.
Petitioner-husband testified that when his father died, he
removed $50,000 from his stepmother's property without telling
her. Both petitioners instructed the masseuses not to tell
others of the correct amount of income they earned. Petitioners'
testimony frequently was implausible, inconsistent, or showed
that they had a propensity for unscrupulous behavior.
This badge of fraud applies to both petitioners for each
year in issue.
f. Dealings in Cash and Cashier's Checks
Petitioners dealt extensively in cash to avoid scrutiny of
their finances, a factor which can suggest fraud. Bradford v.
Commissioner, 796 F.2d at 308. Petitioner-husband used cashier's
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