Estate of Frank Johnson - Page 140




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                    (4)  Dealings in Cash                                             
               Respondent contends that the fact that Frank and Katherine             
          dealt exclusively in cash is another indicium of fraud.                     
          Petitioners contend that Frank and Katherine always conducted               
          their transactions in cash because they were illiterate and                 
          because they learned the practice of using cash from their                  
          parents.  Respondent maintains, however, that only self-serving             
          evidence indicates that Frank and Katherine dealt in cash because           
          of illiteracy.  Respondent contends that Frank and Katherine                
          could have used a checking account system as evidenced by the               
          facts that they obtained mortgages and loans, had competency in             
          adding numbers, could keep some records, could sign their names,            
          and could read and write to some degree.                                    
               There is no evidence that Frank and Katherine could not have           
          used banks to deposit receipts and pay expenditures.  Nor do                
          petitioners explain why Sylvia did not maintain a checking                  
          account system for Frank and Katherine while she lived with them.           
          Frank and Katherine made numerous and substantial cash                      
          expenditures for real property and luxury automobiles.  We agree            
          with respondent that their extensive use of cash for those types            
          of expenditures supports a reasonable inference that Frank and              
          Katherine knowingly and willfully attempted to conceal taxable              
          income.                                                                     








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