- 27 -27 Other badges of fraud include concealing assets, extensive dealings in cash, Recklitis v. Commissioner, supra at 910, failure to file timely returns, Kotmair v. Commissioner, 86 T.C. 1253, 1261 (1986), and failure to provide tax return preparers with complete and accurate information, Korecky v. Commissioner, 781 F.2d 1566, 1569 (11th Cir. 1986), affg. T.C. Memo. 1985-63. Ferrentino presented a cash hoard of $122,600 to the Federal Reserve Bank in Buffalo, New York. According to the required Currency Transaction Report, $75,000 of the amount presented was in bills of $100 or higher. The record indicates that when Ferrentino cashed the Custom Decorating and fuel reimbursement checks, Manufacturer's Hanover would generally cash the checks in $100 denominations. During audit, Ferrentino told Revenue Agent Oswald: (1) He did not report the cash hoard as income, (2) he knew that the source of the cash hoard constituted taxable income, and (3) he called the cash hoard pocket monies. At trial, Ferrentino explained that he had accumulated the cash hoard over a period of 15 to 18 years. He further testified that the cash hoard resulted from the selling and restoration of furniture and that he accumulated the cash hoard in anticipation of his divorce. Based on the amount of $100 bills presented to the Federal Reserve Bank and the fact that Ferrentino received $100 bills when cashing the checks at Manufacturer's Hanover, we may justifiably infer that part of Ferrentino's cash hoard was attributable to the cashed checks. We may further infer thatPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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