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intent to fraudulently evade their 1991 through 1995 income tax
liabilities.
4. Concealing Assets
Concealing assets or income is also an indicium of fraud.
Douge v. Commissioner, 899 F.2d at 168; Bradford v. Commissioner,
796 F.2d 303 (9th Cir. 1986); Recklitis v. Commissioner, 91 T.C.
at 910. Respondent contends, and we agree, that petitioners took
affirmative steps to conceal their income and assets.
Petitioners formed the Elknur Family Limited Partnership and
transferred legal title to their personal residence to the
partnership. Petitioners formed the partnership a mere 7 days
after Revenue Agent Andrews notified Mr. Runkle that the years
1991, 1992, and 1993 were under examination. Petitioners also
caused the Elknur Family Limited Partnership to acquire assets
that have inherent personal recreational value to petitioners,
including the Coachman recreational vehicle for $46,000, a
Kawasaki jet ski, and a trailer. They also created a partnership
checking account to which Mr. Runkle deposited insurance
commission checks and from which petitioners paid personal
expenses, including doctor bills and personal loan payments. As
the general partners of the Elknur Family Limited Partnership,
petitioners had continued control of the partnership, and we find
that petitioners used the partnership to conceal their assets and
frustrate respondent’s collection efforts.
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