Reaves Livestock, Inc., et al. - Page 39

                                       - 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 to                   









Page:  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