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(5) Concealing Transactions
Respondent contends that Frank’s and Katherine’s dealings in
cash and their failure to file any gift tax returns enabled them
to conceal transfers of property from respondent until long after
those transactions occurred. Respondent asserts that the
concealment of assets is another indicium of fraud.
Petitioners assert that there is no evidence that Frank or
Katherine concealed any of the gifts they made to Larry, Ronnie,
and Sylvia. Petitioners, however, do not allege that Frank or
Katherine filed gift tax returns for the substantial gifts they
admittedly gave to their children and grandchildren during the
years in issue, nor do petitioners explain why Frank or Katherine
failed to file gift tax returns relating to those gifts.
Petitioners further assert that the fact that Frank and Katherine
purchased assets for Larry, Ronnie, and Sylvia that were easy to
trace (such as real estate and automobiles) shows that Frank and
Katherine did not intend to conceal any transfers. Petitioners
apparently overlook the fact that for the most part Frank and
Katherine gave Larry, Ronnie, and Sylvia cash to purchase those
assets, many of which were titled solely in Larry’s, Ronnie’s,
and Sylvia’s names thereby making it difficult to trace the cash.
We agree with respondent that Frank and Katherine tried to
conceal their unreported income by giving Larry, Ronnie, and
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