- 29 - offered a credible explanation of the source of the very large amounts of cash at Mr. Karcho’s disposal during this period. As for fraudulent intent for each of the years in issue, we believe petitioners’ maintenance of two sets of books, and their providing the erroneous version to their accountant for tax reporting purposes in each year, is virtually conclusive on the question of fraudulent intent in each year. In any event, there are additional indicia of fraud, including the extended period in which income was understated, the extensive dealings in cash and cashier’s checks that were obviously designed to circumvent currency-reporting requirements, and Mr. Karcho’s admitted misrepresentations to local authorities in an effort to reduce his licensing fees. Finally, Mr. Karcho’s section 7201 conviction with respect to 1987 estops him from denying fraudulent intent in that year. We also conclude that respondent has established that some portion of the underpayment is attributable to the fraud of each petitioner. Although petitioners argue that Mrs. Karcho did not commit fraud, we believe the evidence shows that Mrs. Karcho was intimately involved in the fraudulent record keeping in each year. It was Mrs. Karcho, who was employed as a billing system analyst, who prepared the false records given to the accountant, which records were designed to deceive because they purported to break down the bank deposit amounts into fictitious subtotalsPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011