- 40 - 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.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
Last modified: May 25, 2011