- 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 that
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