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the revocation resolution because respondent did not show that
respondent had possession of all of SCB’s documents relating to
Camaro’s accounts. We disagree. A letter from the legal
department of SCB dated September 29, 1997, states that the bank
does not have a copy of Camaro’s December 13, 1983, resolution.
Petitioners point out that petitioner did not write checks
on Camaro’s SCB accounts while he had signature authority over
those accounts. That fact is not significant because petitioner
could and did direct Choy to make transfers from the Camaro
accounts to him or on his behalf.
A taxpayer’s use of a complex scheme to divert income from
his corporation to third parties he controls may be evidence of
the taxpayer’s attempt to conceal income. Bradford v.
Commissioner, 796 F.2d 303, 307-308 (9th Cir. 1986), affg. T.C.
Memo. 1984-601. Petitioner arranged for payments from NSA to
bypass TCM and instead to be paid to Camaro and for payments from
various sources, including Midtex Relays, to bypass TCM and be
paid to Double D or petitioner.
A taxpayer's diversion of corporate funds for his or her
personal use is evidence that the taxpayer committed fraud.
Solomon v. Commissioner, 732 F.2d 1459, 1460-1461 (6th Cir.
1984), affg. T.C. Memo. 1982-603; United States v. Brill, 270
F.2d 525, 527 (3d Cir. 1959). Petitioner used Camaro to divert
NSA payments to himself and to his family and friends through an
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