- 28 -
Wendy Arbogast was one of petitioner’s clients. Ms.
Arbogast testified that she had purchased a bird from petitioner
for $1,400 but paid $800 of the purchase price in cash. Ms.
Arbogast testified that petitioner told her when she started
going to him for veterinary services that he preferred cash
payments.
3. Use of Nominee Accounts
Use of nominees to conceal assets that a taxpayer has
unfettered control over is evidence of fraud. See Friedman v.
Commissioner, T.C. Memo. 1968-145, affd. 421 F.2d 658 (6th Cir.
1970).
Petitioner received checks from various customers for
providing veterinarian services, the sale of animals, and
royalties and deposited them into various bank accounts fashioned
as trustee accounts. These deposits were derived from income
earned by and taxable to petitioner. The accounts were fashioned
as trust accounts in an effort by petitioner to disguise the true
ownership of the accounts.
4. Failure To Cooperate With Revenue Agents
Failure to cooperate with revenue agents during the audit
phase of a case is an additional indication of guilty knowledge
on a taxpayer’s part. See Professional Servs. v. Commissioner,
79 T.C. 888, 933 (1982).
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 NextLast modified: May 25, 2011