- 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 byPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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