Dennis E. Runkle and Debra A. Runkle - Page 25

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          intent to fraudulently evade their 1991 through 1995 income tax             
               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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