-27- records is evidence of fraud. See Bradford v. Commissioner, supra at 307. Second, during each of the years in issue, petitioner used the same incorrect Social Security number on the invoices he submitted to, and on his contracts with, general contractors for construction projects. In many circumstances, the use of an incorrect Social Security number could be evidence of nothing more than negligence or mistake. However, in this case it is clear that petitioner at one time knew his correct number, because he used it on his 1973, 1974, and 1975 returns. In light of these and the other facts in the record, petitioner's consistent use of an incorrect Social Security number, during a 6-year period, with respect to hundreds of thousands of dollars of business receipts, is relevant evidence of concealment and fraud. Third, petitioner made extensive use of cash during the years 1989-92. Dealing in cash may also be evidence of fraud. See Bradford v. Commissioner, supra at 308. Fourth, as we discuss infra pp. 39-40, it is also clear that petitioner did not pay any estimated taxes for 1989-92. This is also an indication of fraud. See Bradford v. Commissioner, supra at 796 F.2d. 3. Petitioner's Use of a Bahamian Bank Account We now consider the admissibility of evidence of certain other facts, which respondent claims are circumstantial evidence of fraud.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011