- 37 - 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.Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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