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e. Concealment of Income or Assets
The concealment of income or assets is an indicium of fraud.
Bradford v. Commissioner, supra at 307-308.
The facts clearly show that petitioner concealed substantial
amounts of income by his actions. During the civil examination
by Ms. Davis, the revenue agent, petitioner did not furnish any
statements to her pertaining to his Shearson investment account
until she discovered a canceled check payable to Shearson. In
addition, he never provided statements to Ms. Davis regarding his
investment account at the Howard, Weil Company, despite
substantial deposits made to it.
Petitioner intended to conceal income by cashing some 300
checks at Circle Food Store and Liberty Bank, rather than First
Federal, his own bank, and then telling Mr. Bruno, his
accountant, and Ms. Davis that all income checks he received from
attorneys were deposited into his First Federal checking account.
Furthermore, petitioner did not tell Mr. Bruno or Ms. Davis
that he exchanged checks from attorneys for First Federal bank
checks, that the exchange would not be reflected in his First
Federal checking account, and that he deposited the bank checks
into his investment accounts. Without such information neither
Mr. Bruno nor Ms. Davis would have known that the income existed.
Thus, petitioner withheld necessary information that misled his
accountant and the revenue agent.
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