- 35 -
checking account. These items represent nondeductible personal
expenses.
C. Conclusion
We conclude that respondent has shown that Beck's Liquors
and Mr. Beck underpaid taxes in all the years at issue.
II. Intent To Evade Taxes
The Commissioner must prove by clear and convincing evidence
that the taxpayer intended to evade taxes by conduct intended to
conceal, mislead, or otherwise prevent tax collection. Stoltzfus
v. United States, 398 F.2d 1002, 1004 (3d Cir. 1968); Parks v.
Commissioner, 94 T.C. at 661; Rowlee v. Commissioner, 80 T.C.
1111, 1123 (1983).
A corporation is liable for fraud if the corporate officer
has the fraudulent intent to evade the corporation's taxes.
DiLeo v. Commissioner, 96 T.C. 858, 875 (1991), affd. 959 F.2d 16
(2d Cir. 1992); Federbush v. Commissioner, 34 T.C. 740, 749
(1960), affd. 325 F.2d 1 (2d Cir. 1963); Mazzocchi Bus Co. v.
Commissioner, T.C. Memo. 1993-43, affd. 14 F.3d 923 (3d Cir.
1994). The fraudulent intent of Beck's Liquors may be
established by the acts of its president, Mr. Beck, who
completely dominated its activity.
Fraud means "actual, intentional wrongdoing", Mitchell v.
Commissioner, 118 F.2d 308, 310 (5th Cir. 1941), revg. 40 B.T.A.
424 (1939), or the intentional commission of an act or acts for
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