- 39 - First Citizens checks that were income to them. This badge of fraud applies to Mr. and Mrs. Reaves for 1984, 1985, 1986, and 1987, because they both did not maintain accurate records in each of those years. c. Dealing in Cash to Conceal Income A taxpayer's use of cash to conceal income is evidence of fraud. Bradford v. Commissioner, supra. Mr. Reaves used the 282 checks to obtain cash which was concealed income. Mrs. Reaves used the John Chavis checks to obtain cash which was concealed income. This badge of fraud applies to Mr. and Mrs. Reaves for 1984, 1985, 1986, and 1987, because they used cash to conceal income in each of those years. d. Using a Fictitious Name Using a fictitious name may be evidence of fraud. Lipsitz v. Commissioner, 21 T.C. 917, 937 (1954), affd. 220 F.2d 871 (4th Cir. 1955). The 282 checks were written to fictitious payees. Mr. Reaves endorsed one of the checks in 1986. His endorsement of that check is a badge of fraud for him for 1986. Mrs. Reaves signed some of the 282 checks for Reaves Livestock in 1984, 1985, 1986, and 1987, and endorsed some of them in 1985 and 1986. She also cashed checks written toPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
Last modified: May 25, 2011