Albert M. Graham and Martha A. Graham - Page 44

                                       - 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  Next

Last modified: May 25, 2011