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multiple deductions of the same amounts is inconsistent with his
spreadsheets, which show that he entered the same amounts more
than once on his spreadsheets.
d. Failure To Cooperate With Tax Authorities
A taxpayer’s failure to cooperate with the Commissioner’s
examining agents is a badge of fraud. Bradford v. Commissioner,
supra. Petitioners did not meet with Hughs as she requested or
provide the substantiation she requested. We conclude that
petitioners did not cooperate with Hughs.
e. Having False or Inadequate Books and Records
A taxpayer’s failure to maintain accurate records or
concealment of records may be a badge of fraud. Id. at 308;
Merritt v. Commissioner, 301 F.2d 484, 487 (5th Cir. 1962), affg.
T.C. Memo. 1959-172; Reaves v. Commissioner, 295 F.2d 336, 338
(5th Cir. 1961), affg. 31 T.C. 690 (1958); Grosshandler v.
Commissioner, supra. As discussed above, petitioners failed to
produce, and thus we infer that they failed to keep, records
substantiating their deductions.
3. Whether Petitioner’s Deduction of $16,500 TruGreen Paid
to Nelson Hesse or $471.45 Paid to an Individual Not
Otherwise Identified in the Record Was Fraudulent
Respondent contends that petitioner’s deductions for 2000 of
$16,500 paid to Nelson Hesse for legal and professional services
and $471.45 paid to an individual not otherwise identified in the
record were fraudulent for the same reasons that his deductions
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