-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 NextLast modified: May 25, 2011