- 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 Next
Last modified: May 25, 2011