Mahendra K. Tandon - Page 29

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               Although not dispositive, petitioner's convictions under               
          section 7206(1) are probative evidence that he intended to evade            
          his taxes.  See Wright v. Commissioner, 84 T.C. 636, 643-644                
                    7.   Other Factors                                                
               A taxpayer's practice of regularly depositing large portions           
          of his business receipts from his sole proprietorship into his              
          personal bank accounts may be evidence of fraud.  See Farber v.             
          Commissioner, 43 T.C. 407 (1965), supplemented by 44 T.C. 408               
          (1965).  During the years in issue, petitioner regularly                    
          deposited large amounts of receipts from his medical practice               
          (whether it was a sole proprietorship or a corporation) into his            
          personal bank accounts; e.g., the AT #4 account, the AT #9                  
          account, and the Society National Bank account.  Petitioner made            
          these deposits in an attempt to conceal his income.  This is                
          evidence of fraud.                                                          
               C.   Conclusion                                                        
               After reviewing all of the facts and circumstances, we                 
          conclude that respondent has clearly and convincingly proven                
          that all of the underpayments of tax resulting from petitioner's            
          unreported medical practice income and rental income for each of            
          the years in issue were due to fraud on the part of petitioner.             
          Therefore, we sustain respondent's determination that petitioner            
          is liable for additions to tax for fraud pursuant to section                
          6653(b) for 1985, 1986, 1987, and 1988.                                     

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