-41- 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'sPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
Last modified: May 25, 2011