- 44 -
F.2d 809 (2d Cir. 1959), affg. T.C. Memo. 1957-77; Am. Rolbal
Corp. v. Commissioner, 220 F.2d 749 (2d Cir. 1955), affg. per
curiam T.C. Memo. 1954-67; Hicks Co. v. Commissioner, 56 T.C.
982, 1019, 1030 (1971), affd. 470 F.2d 87 (1st Cir. 1972); Benes
v. Commissioner, 42 T.C. 358, 383 (1964), affd. 355 F.2d 929 (6th
Cir. 1966). Petitioners deducted personal expenses as business
expenses on their 1998 and 1999 returns, such as payments to
American Express for petitioner’s wife’s bills, Best Buy for new
appliances for petitioners’ Big Bear cabin, Interiors for
remodeling work done on petitioners’ cabin, Big Bear Glass to buy
materials for petitioners’ cabin, and Union Bank of California to
buy two cashier’s checks to pay petitioners’ personal taxes. We
reject petitioners’ attempt to blame Edgar for their deduction of
personal expenses as business expenses because petitioners
continued to improperly deduct personal expenses, such as
payments to their home gardener and to Kim Sterling for flowers,
in 1999 after Edgar left, and we believe Edgar’s testimony that
she did what petitioner told her to do.
f. Concealing Income Through a Complex Series of
Transactions and Nominees
A taxpayer’s use of a complex series of financial
transactions and nominees may be evidence of the taxpayer’s
attempt to conceal income and remove it from the Government’s
reach. Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th Cir.
1986), affg. T.C. Memo. 1984-601. Petitioner concealed income by
Page: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 NextLast modified: May 25, 2011