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fictitious persons (Ray Hunt and John Chavis) in 1984, 1985,
1986, and 1987.
Mr. Reaves opened the S&J account with a Social Security
number that was neither his nor Mrs. Reaves'. Mr. Reaves
speculated that it might have been Prevatte's, but he also said
that he did not know. This is a badge of fraud for Mr. Reaves.
This badge of fraud applies to Mr. and Mrs. Reaves for 1984,
1985, 1986, and 1987, because they both used fictitious names in
each of those years.
e. Concealing Income from Return Preparers
Concealing income from a taxpayer's return preparer can be
evidence of fraud. Korecky v. Commissioner, 781 F.2d 1566, 1569
(11th Cir. 1986), affg. T.C. Memo. 1985-63; Farber v.
Commissioner, 43 T.C. 407, 420 (1965), modified 44 T.C. 408
(1965). Davis did not know about the First Citizens accounts or
John Chavis checks or know that the 282 checks were written to
fictitious payees when he filed Mr. and Mrs. Reaves' returns for
the years in issue. Mr. Reaves did not tell Davis about any of
these items. Mrs. Reaves gave Mr. and Mrs. Reaves' personal
return information to Davis, but she did not tell Davis about the
First Citizens accounts or the John Chavis checks.
Petitioners contend that Davis had access to all of their
records and should have taken them into account. We disagree.
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