Evidences of Fraudulent Intent

Evidences of Fraudulent Intent:

The following factors, when discovered upon audit or otherwise, are considered to be evidence of fraudulent intent:

... a substantial disparity between large bank deposits and small reported gross income.

... buying multiple motor vehicles in each of the tax years under examination, plus cash investment in a trailer park. These actions were inconsistent with income level reported on taxpayer's tax returns.

... an attempt to conceal the existence of bank deposits.

... taxpayer, who failed to file a return, maintained only non-interest bearing bank accounts, since he knew that banks report interest payments to the Federal government.

... taxpayer threatened third parties with civil suits should they comply with IRS summonses.

... inadequate records especially in cases involving very substantial underpayments.

... taxpayer overvalued art contributed to charity. He had insured the art for its real market value, i.e., an amount much lower than the amount of his tax deduction, and claimed that the reason he insured it for that lesser amount was that he couldn't afford to insure it for its full value. But he also advised the charity to insure the piece for that lower amount, which convincingly illustrated that he knew his claimed deduction was inflated.

... tax shown on return was equal to the penny to the amount of tax withheld from wages indicating that the figures had been juggled.

... abnormal banking procedures, such as frequent overdrafts covered with cash deposits and no regularity in depositing of daily receipts.

... currency was used instead of bank accounts in business operations.

... taxpayer attempted to conceal his income and avoid the reporting requirement for large cash transactions by depositing funds (just under $10,000 on any given day) from the operation of a recreational complex into a bank account which was opened in the name of another person but was controlled by the taxpayer. Also, the taxpayer had inadequate records, made up conflicting testimony with his cohorts in the hopes of misleading the court, and refused to provide records to IRS.

... taxpayer did not report full withholding tax on wages paid to employees and did not record and deduct full wages paid to them.

... omission should have been readily apparent to the taxpayer when he examined his return where it involved operation of a liquor business for part of the year for which records had been kept.

... unreported income of stockholder-officer consisted of corporate funds appropriated by the taxpayer over a period of years.

... taxpayer, an attorney, made misleading statements to IRS's agents during the course of their criminal investigation, and failed to provide copies of delinquent returns and produce records.

... taxpayer did not cooperate with IRS agents, making it necessary for IRS to determine his income from third party sources.

... taxpayer failed to cooperate with the special agent and bragged about his failure to file returns for prior years (apparently believing that those years were closed). Taxpayer was an attorney well versed in tax matters and had failed to file returns.

... no estate tax return was filed by the executors even though they knew that decedent owned substantial assets at the time of his death.

... improper estate tax deduction of undelivered and uncashed checks as debts of the estate. One of the daughters wrote the checks on the decedent's bank account. The court didn't accept the explanation that the deduction resulted from a miscommunication between the preparer (husband of one of the decedent's daughters) and the daughters because the estate tax return falsely indicated that the checks "cleared after death". Also, there were insufficient funds in the bank account to cover the checks.

... failure to file a tax return until after IRS notified the taxpayer that it was investigating his failure to file the return.

... taxpayer gave false or incomplete records to revenue agent or was uncooperative.

... taxpayer made false statements to IRS agents regarding income on bank accounts.

... executor excluded stock from mother's estate and attempted to conceal the fact by claiming he purchased stock after death.

... property acquisitions were predated in order to get long term capital gains and deductions were inflated.

... co-owners of incorporated car dealership appropriated cash receipts and proceeds from sales of trade-ins and omitted those amounts both from corporate and individual returns.

... omission from stockholder's income of building erected for him by his corporation and charged to corporation's ordinary expenses.

... an experienced businessman's attempt to conceal that he lived in a house owned by his wholly-owned corporation and that he commingled other business and personal assets in order to evade taxes.

... entire receipts from one of two offices operated by doctor omitted resulting in a very large understatement of income.

... use of corporate funds for personal purposes claimed as loans.

... taxpayer-attorney created a sham sale-repurchase of stock for the sole purpose of generating a capital loss to offset an unrelated capital gain.

... sales made directly from taxpayer's warehouse were not recorded, which information was withheld from taxpayer's own bookkeeper.

... taxpayer used an alias and a false social security number in applying for a post office box which he used for correspondence relating to the sale of stolen computer equipment, and falsified receipts to show that he had bought equipment stolen from his employer.

... taxpayer omitted interest income and told IRS agent that he had no savings accounts; he claimed capital losses from stock sales where his only receipts showed unreported capital gains; he produced altered documents to prove charitable contributions.

... taxpayers contended that their minor children were the owners or income recipients of a pyramid scheme and commodity account when in fact IRS demonstrated that a substantial portion of the proceeds from the pyramid scheme and from commodity gains were used for taxpayers' home and vacation homes.

... consistent omission of the misappropriated funds, the extent to which taxpayer went to conceal these misappropriations, combined with his knowledge of tax matters.

... omission of payment received as political contribution, for using influence to procure liquor license renewal for contributor but never turned over to party campaign fund.

... a casino dealer's failure to report any toke (tip) income and then falsely claiming that she worked as a floor person who received wages (but not tips) for most of the year.

... cash concealed in safe deposit box for unconvincing reasons.

... inadequate tax records in contrast to great care in otherwise handling personal financial affairs.

... failure to keep records of gambling activities resulting in substantial profits.

... taxpayer was a narcotics dealer which suggested to the Tax Court a willingness to conceal income from the government with intent to evade taxes.

... convicted drug dealer used fictitious names, operated legitimate businesses as "fronts" for his narcotics operations, and admitted to destroying whatever records he may have maintained relating to his illegal activities.

... corporation was charged with fraud penalty where office pleaded guilty to criminal fraud indictment. The corporation kept only haphazard records in which the officer failed to record a portion of company income.

... fraudulent activities of shareholder were imputed to corporation which was charged with fraud. Shareholder diverted corporate funds to purchase securities and claimed interest deduction for interest on loans from the corporation (where he never intended to enter into a bona fide debtor-creditor relationship).

... failure to record fees or names of patients (by a doctor) or existence of bank accounts.

... omission of a number of different income items, such as income from a timber deal, interest income from notes, and profit from the sale of equipment.

... taxpayer, who failed to report over $1 million in income (which was obtained from sources related to a scheme that defrauded more than 28,000 investors out of $80 million), pled guilty to disseminating false advertisements through the mail and transferred company funds to nominees inside and outside of the U.S. through a series of complex financial transactions in an attempt to conceal the income.

... payment of principal stockholder's personal expenses and deducting them as business expenses.

... taxpayer, who supplied funds to her in-laws' inactive business checking account and then used those funds to pay the cost of restoring a mansion, in an attempt to conceal her income. She then had her mother-in-law execute a misleading affidavit as to the source of the funds. Other indicia of fraud were the taxpayer's use of cash to make purchases although she had many bank checking accounts, and the fact that she went along with the preparation of false invoices.

... sole proprietor deposited large portions of business receipts into personal bank accounts without putting them into business records.

... taxpayer, an attorney, kept haphazard records, omitted from income a significant number of cash fees, and cashed many checks for fees at establishments other than the bank which held his business bank account.

... taxpayers claimed a nonexistent net operating loss carryover.

... taxpayers provided their return preparer with substantially corrected business income amounts once they were notified that their returns were going to be examined.

... taxpayers received "under the table" cash payments. The court said these had long been held to be indicia or badges of fraud.

... taxpayer made knowingly false statements to U.S. Postal Inspectors relating to amounts misappropriated from his employer by submitting phony invoices. The failure of the taxpayer to report this income on his tax return and the fact that much of taxpayer's income came from illegal kickbacks supported a finding of fraud.

... consistent omission of funds extorted by teamster union officials as protection money, dealing in cash and through an intermediary, and threatening a witness if he testified against the taxpayer.

... conviction of a former IRS agent for conspiracy to defraud the U.S. by accepting bribes in exchange for favorable treatment of his co-conspirators during audits. Since the agent knew that bribes are income, he intended to evade tax by not reporting his bribe income.

... taxpayer ignored advice that embezzled funds were taxable and failed to report them.

... substantial understatements of income by knowledgeable taxpayer.

... failure to record certain transactions such as sales, etc., on firm's books.

... deduction of personal expenses as business expenses.

... actively practiced deception such as use of false names or addresses.

... taxpayers kept no records, appropriated funds belonging to others to his personal use, was convicted of gross theft, filed no tax returns, and was knowledgable about tax law.

... tax return preparer diverted 110 Federal income tax refund checks to his own benefit remitting a much smaller amount to taxpayers.

... taxpayer over a period of two years didn't report over $250,000 of income earned from a series of kickbacks.

... numbers business operator misrepresented his occupation on his tax return as "retired" and used evasive tactics and false explanations during audit.

... taxpayer failed to provide his tax preparers with adequate or accurate information.

... taxpayer overstated his deductions, which he simply conceded at trial without explanation. Also he submitted altered documents to IRS agents in an attempt to defraud.

... taxpayer filed false withholding certificates.

... taxpayer altered the W-2 he attached to his return.

... taxpayer claimed fictitious deductions when in fact most of the money was invested in bankers acceptances and later used to pay off bank loans that supposedly represented the source of funds for the deductions.

... taxpayer didn't file returns for 15 consecutive years, operated exclusively in cash, didn't have any bank accounts, and tried to transfer funds out of the country by using his alias.

... taxpayer's inconsistencies and evasiveness when he testified in court and his lack of credibility were factors used to find fraud.

... taxpayer claimed a church had sold his insurance agency which included $115,000 paid by buyer for a covenant not to compete. Taxpayer's purported vow of poverty was apparently executed only after he had received four payments, totalling $68,000 from the buyer.

... taxpayers transferred their funds to a church they formed that had as its basic doctrine resistance to the collection of Federal income tax, and used these funds to pay their personal bills.

... a "Universal Life Church" (ULC) minister's claim of charitable contribution deductions for amounts transferred to a checking account registered to the ULC in a tax avoidance scheme. However, he never transferred the funds to the ULC and knowingly used the funds to pay nondeductible personal expenses.

... taxpayers each attempted to convince their employers to accept false withholding certificates. The husband reduced the number of exemptions on his W- 4 form only after his boss threatened to fire him if he did not. They refused to provide information to the IRS or the Tax Court.

... taxpayer filed a false Form 1040, which indicated that his wages were "under $2,100," after he had received Forms W-2 indicating otherwise.

... failure to file tax returns and keep records by taxpayer whose sole proprietorship was engaged in tax return preparation and bookkeeping service for others. She produced phony duplicates of tax returns which she represented to have filed.

... omission of sales proceeds (from real estate sales and from auction of collectibles) of over $45,000; failure to maintain adequate records; and taxpayer's evasiveness when interviewed by an IRS agent.

... secretly taped statements of the a major shareholder-officer of a corporation relating to the diversion of substantial amounts of cash received by the corporation (from drug smugglers and other clients who preferred that their transactions go unreported) to the shareholder's personal use. These statements indicated that the shareholder knew of the diversions of income, and that he intended to conceal income and evade the payment of tax. Additional evidence of taxpayer's fraudulent intent included the intentional destruction and consistent falsification of business records, taxpayer's refusal to cooperate with IRS, and the consistent (six year) and substantial (more than 1.7 million) underreporting of income. 

Meyers, Leota, (1946) PH TCM ¶46074, 5 CCH TCM 211; Puritan Church of America, (1951) PH TCM ¶51151, 10 CCH TCM 485, affd (1953, CA Dist Col) 45 AFTR 119, 209 F2d 306, 53-2 USTC ¶9601, cert den (1954, S Ct) 347 US 975, 98 L Ed 1115, reh den (1955, S Ct) 48 AFTR 675, 350 US 890, 100 L Ed 784 .

Carroll, Henry, (1995) TC Memo 1995-28.

Winer, H., (1954) TC Memo 1954-148, PH TCM ¶54254, 13 CCH TCM 858.

Marsellus (a/k/a C. West Marsellas) v. Com., (1977, CA5) 39 AFTR 2d 77-595, 544 F2d 883, 77-1 USTC ¶9129, reh den (1977, CA5) 546 F2d 906, affg (1975) TC Memo 1975-368, PH TCM ¶75368, 34 CCH TCM 1581.

Wilber, David Byron, (1987) TC Memo 1987-439, PH TCM ¶87439, 54 CCH TCM 380, affd (1988, CA8) 871 F2d 1092.

Bond, V.F. v. Com., (1956, CA4) 49 AFTR 1001, 232 F2d 822, 56-1 USTC ¶9471, cert den (1956, S Ct) 352 US 878, 1 L Ed 2d 79; (1954) PH TCM ¶54036, 13 CCH TCM 82, affd & revd (1955, CA8) 47 AFTR 947, 222 F2d 878, 55-1 USTC ¶9482 ; Estrella, Victor, (1954) TC Memo 1954-127, PH TCM ¶54233, 13 CCH TCM 800 ; Warten, Henry, (1954) PH TCM ¶54095, 13 CCH TCM 329 ; Murray, Arthur, (1956) TC Memo 1956-31, PH TCM ¶56031, 15 CCH TCM 141 ; Hicks Co, (1971) 56 TC 982, affd (1972, CA1) 31 AFTR 2d 73-382, 470 F2d 87, 73-1 USTC ¶9109 .

Angell, Joseph, (1986) TC Memo 1986-528, PH TCM ¶86528, 52 CCH TCM 939.

McCarthy, Daniel, (1957) TC Memo 1957-194, PH TCM ¶57194, 16 CCH TCM 879.

Agnellino, Anthony v. Com., (1962, CA3) 9 AFTR 2d 1423, 302 F2d 797, 62-1 USTC ¶9461.

Lusk, William, (1955) TC Memo 1955-119, PH TCM ¶55119, 14 CCH TCM 435, affd (1957, CA7) 52 AFTR 1097, 250 F2d 591, 57-2 USTC ¶10023, cert den (1958, S Ct) 357 US 932, 2 L Ed 2d 1375.

Sea Sports Center Inc, (1991) TC Memo 1991-209, TC Memo ¶91209, 61 CCH TCM 2597, affd (1992, CA11) 979 F2d 1537.

Santuccio, Salvatore Est, (1952) PH TCM ¶52102, 11 CCH TCM 343.

Wilson, Monroe, (1956) TC Memo 1956-53, PH TCM ¶56053, 15 CCH TCM 229.

Federbush, Irving, (1960) 34 TC 740, affd (1963, CA2) 12 AFTR 2d 6069, 325 F2d 1, 64-1 USTC ¶9107.

Weisensee, Lawrence Anthony, (1987) TC Memo 1987-206, PH TCM ¶87206, 53 CCH TCM 643.

Gifford, A. Grover, (1980) TC Memo 1980-351, PH TCM ¶80351, 40 CCH TCM 1115.

Nachison, Harold, (1981) TC Memo 1981-113, PH TCM ¶81113, 41 CCH TCM 1079.

Edens, William Jr. Est, (1981) TC Memo 1981-557, PH TCM ¶81557, 42 CCH TCM 1254, affd per curiam, (1982, CA4) 51 AFTR 2d 83-1316.

Stimson, Harold Est, (1992) TC Memo 1992-242, RIA TC Memo ¶92242, 63 CCH TCM 2855.

Fedechko, Dennis, (1990) TC Memo 1990-390, PH TCM ¶90390, 60 CCH TCM 272.

Klassie, Samuel v. U.S., (1961, CA8) 7 AFTR 2d 1190, 289 F2d 96, 61-1 USTC ¶9389; Lusk, William, (1955) TC Memo 1955-119, PH TCM ¶55119, 14 CCH TCM 435, affd (1957, CA7) 52 AFTR 1097, 250 F2d 591, 57-2 USTC ¶10023, cert den (1958, S Ct) 357 US 932, 2 L Ed 2d 1375 ; Ringler, Jane, exrx, (1956) TC Memo 1956-77, PH TCM ¶56077, 15 CCH TCM 396 ; Vise, J.K., (1958) 31 TC 220, affd on other issue (1960, CA6) 5 AFTR 2d 1474, 278 F2d 642, 60-1 USTC ¶9474 ; Sunbrock, Lawrence (a/k/a Larry Sunbrock), (1967) 48 TC 55 ; Duncan, Robert, (1987) TC Memo 1987-392, PH TCM ¶87392, 54 CCH TCM 98 ; Popkin, Marvin, (1988) TC Memo 1988-459, PH TCM ¶88459, 56 CCH TCM 294 ; Walters, Roy, (1988) TC Memo 1988-530, PH TCM ¶88530, 56 CCH TCM 664 .

Perry, L.D., (1978) TC Memo 1978-451, PH TCM ¶78451, 37 CCH TCM 1847-44; DiPiazza, Albert Jr., (1978) TC Memo 1978-422, PH TCM ¶78422, 37 CCH TCM 1749 ; Bolden, Gladys, (1978) TC Memo 1978-294, PH TCM ¶78294, 37 CCH TCM 1232 ; Reynolds, Don, (1977) TC Memo 1977-181, PH TCM ¶77181, 36 CCH TCM 756 ; McDowell, Walter, (1987) TC Memo 1987-186, PH TCM ¶87186, 53 CCH TCM 536 ; Light, Edward, (1987) TC Memo 1987-572, PH TCM ¶87572, 54 CCH TCM 1102 ; Smith, Lawrence E., (1989) TC Memo 1989-257, PH TCM ¶89257, 57 CCH TCM 531 .

Pittard, John, (1977) 69 TC 391.

High, Paul, (1956) TC Memo 1956-18, PH TCM ¶56018, 15 CCH TCM 91.

Logan Square Auto Mart Inc, (1960) TC Memo 1960-6, PH TCM ¶60006, 19 CCH TCM 19, affd (1961, CA7) 7 AFTR 2d 1459, 291 F2d 136, 61-2 USTC ¶9490.

Western Supply & Furnace Co, (1959) TC Memo 1959-57, PH TCM ¶59057, 18 CCH TCM 288, affd (1961, CA7) 8 AFTR 2d 5615, 295 F2d 341, 61-2 USTC ¶9700.

Walton, William v. U.S., (1990, CA6) 66 AFTR 2d 90-5379, 909 F2d 915, 90-2 USTC ¶50429 .

Martin, Clinton Est v. Com., (1959, CA2) 4 AFTR 2d 5935, 272 F2d 191, 60-1 USTC ¶9129, affg (1959) TC Memo 1959-20, PH TCM ¶59020, 18 CCH TCM 100.

Reilly, Reginald, (1989) TC Memo 1989-134, PH TCM ¶89134, 56 CCH TCM 1574; Foster, Janie, (1989) TC Memo 1989-276, PH TCM ¶89276, 57 CCH TCM 661 ; Hagaman, William, (1987) TC Memo 1987-549, PH TCM ¶87549, 54 CCH TCM 992, later proceeding (1990) TC Memo 1990-655, PH TCM ¶90655, 60 CCH TCM 1525, affd & remd (1992, CA6) 69 AFTR 2d 92-906, 958 F2d 684, 92-1 USTC ¶50141 .

Henson, Kenneth v. Com., (1989, CA11) 64 AFTR 2d 89-5847, 887 F2d 1520, 89-2 USTC ¶9629.

Daniels, Ballard v. U.S., (1980, CA5) 46 AFTR 2d 80-5019, 617 F2d 146, 80-1 USTC ¶9438.

Collins, Carl, (1991) TC Memo 1991-553, TC Memo ¶91553, 62 CCH TCM 1186 .

Selde, Vernon, (1980) TC Memo 1980-222, PH TCM ¶80222, 40 CCH TCM 533.

Cima, Robert, (1987) TC Memo 1987-284, PH TCM ¶87284, 53 CCH TCM 1028.

Enterline, Frederic, (1980) TC Memo 1980-200, PH TCM ¶80200, 40 CCH TCM 454.

Reichert, Manson, (1953) 19 TC 1027, acq, affd on other issue (1954, CA7) 45 AFTR 1691, 214 F2d 19, 54-2 USTC ¶9442, cert den (1955, S Ct) 348 US 909, 99 L Ed 713.

McGinty, Sarah Elizabeth, (1991) TC Memo 1991-435, TC Memo ¶91435, 62 CCH TCM 654.

Miles, James Est, (1955) TC Memo 1955-75, PH TCM ¶55075, 14 CCH TCM 237; Minor, Henry, (1956) TC Memo 1956-175, PH TCM ¶56175, 15 CCH TCM 906 .

Owens, D.L. v. U.S., (1952, CA8) 42 AFTR 30, 197 F2d 450, 52-2 USTC ¶9376, affg (1951, DC AR) 40 AFTR 1114, 98 F Supp 621, 51-2 USTC ¶9383.

Romer, Herman, (1957) 28 TC 1228, acq.

Cisneros, Pete, (1980) TC Memo 1980-358, PH TCM ¶80358, 40 CCH TCM 1141.

McFarlin, Rex, (1981) TC Memo 1981-563, PH TCM ¶81563, 42 CCH TCM 1276.

Laputka & Sons Inc, M.J., (1981) TC Memo 1981-730, PH TCM ¶81730, 43 CCH TCM 177.

Mitchell, Robert, (1982) TC Memo 1982-162, PH TCM ¶82162, 43 CCH TCM 937.

Schneider, Harry Est, (1958) 29 TC 940, acq; Bowlin, Robert, (1958) 31 TC 188, affd (1960, CA6) 5 AFTR 2d 389, 273 F2d 610, 60-1 USTC ¶9172 ; Reaves, Jesse, (1958) 31 TC 690, acq, affd (1961, CA5) 8 AFTR 2d 5619, 295 F2d 336, 61-2 USTC ¶9703 ; Hicks, Vonnie, (1957) TC Memo 1957-24, PH TCM ¶57024, 16 CCH TCM 108 .

Jenkins, Wilson, exr v. U.S., (1963, CA5) 11 AFTR 2d 868, 313 F2d 624, 63-1 USTC ¶9289.

Taylor, Deborah, (1993) TC Memo 1993-546, RIA TC Memo ¶93546, 66 CCH TCM 1389.

Atlanta Biltmore Hotel Corp v. Com., (1965, CA5) 16 AFTR 2d 5285, 349 F2d 677, 65-2 USTC ¶9573, affg (1963) TC Memo 1963-255, PH TCM ¶63255, 22 CCH TCM 1266.

Brown, Michael, (1991) TC Memo 1991-200, TC Memo ¶91200 .

Farber, Jacob, (1965) 43 TC 407, supp op (1965) 44 TC 408.

U.S. v. Samara, Carroll, (1981, CA10) 47 AFTR 2d 81-955, 643 F2d 701, 81-1 USTC ¶9220.

Technical Industrial Consultants Inc, (1966) TC Memo 1966-150, PH TCM ¶66150, 25 CCH TCM 804.

Kirschner, Edward, (1981) TC Memo 1981-201, PH TCM ¶81201, 41 CCH TCM 1339.

Gualtieri, Frank Jr., (1981) TC Memo 1981-104, PH TCM ¶81104, 41 CCH TCM 1054.

Weil, Louis, (1990) TC Memo 1990-414, PH TCM ¶90414, 60 CCH TCM 407, affd (1992, CA9) 962 F2d 16 .

Grancich, Mike v. Com., (1978) TC Memo 1978-92, PH TCM ¶78092, 37 CCH TCM 424, affd sub nom Archie Galea, (1981, CA9) unpublished op.

Berry, Edward F., (1990) TC Memo 1990-396, PH TCM ¶90396, 60 CCH TCM 292, affd (1991, CA3) 935 F2d 1280.

Hill, Charlotte, (1967) TC Memo 1967-72, PH TCM ¶67072, 26 CCH TCM 371.

Robinson, William v. U.S., (1973, DC PA) 31 AFTR 2d 73-875, 73-1 USTC ¶9278.

Van Valkenburgh, Norman, (1967) TC Memo 1967-162, PH TCM ¶67162, 26 CCH TCM 753; Stein, Ben, (1972) TC Memo 1972-140, PH TCM ¶72140, 31 CCH TCM 663 .

Blunt, C. Harry, (1966) TC Memo 1966-280, PH TCM ¶66280, 25 CCH TCM 1445; Imeson, Joseph, (1950) 14 TC 1151 .

Gilday, John, (1974) 62 TC 260; Yu, Paul, (1973) TC Memo 1973-188, PH TCM ¶73188, 32 CCH TCM 878 .

Walsh, James, (1977) TC Memo 1977-392, PH TCM ¶77392, 36 CCH TCM 1587.

Brown, James, (1981) TC Memo 1981-294, PH TCM ¶81294, 42 CCH TCM 91.

Byrne, Joseph, (1982) TC Memo 1982-373, PH TCM ¶82373, 44 CCH TCM 338.

Jedinak, Edward, (1978) TC Memo 1978-227, PH TCM ¶78227, 37 CCH TCM 965.

Leeper, Lyle, (1979) TC Memo 1979-148, PH TCM ¶79148, 38 CCH TCM 655; Kness, John, (1986) TC Memo 1986-157, PH TCM ¶86157, 51 CCH TCM 881 ; Stobaugh, Leon, (1984) TC Memo 1984-112, PH TCM ¶84112, 47 CCH TCM 1227 .

Robinson, Willie, (1984) TC Memo 1984-188, PH TCM ¶84188, 47 CCH TCM 1510.

Cook, Allen, (1980) TC Memo 1980-415, PH TCM ¶80415, 40 CCH TCM 1334; Best, Bushell, (1981) TC Memo 1981-251, PH TCM ¶81251, 41 CCH TCM 1562 ; Summers, James, (1981) TC Memo 1981-545, PH TCM ¶81545, 42 CCH TCM 1195 .

Hebrank, Steve, (1983) 81 TC 640; Stringer, Ronald, (1985) 84 TC 693, affd (1986, CA4) 789 F2d 917 .

Drobny, Sheldon, (1986) 86 TC 1326.

Tucker, Clinton, (1985, Cl Ct) 8 Cl Ct 180, 85-1 USTC ¶9394.

Toussaint, Andrew, (1984) TC Memo 1984-25, PH TCM ¶84025, 47 CCH TCM 913, affd (1984, CA5) 54 AFTR 2d 84-6092, 743 F2d 309, 84-2 USTC ¶9839.

Merritt, Joe, (1983) TC Memo 1983-218, PH TCM ¶83218, 45 CCH TCM 1368.

Jenny, Kathleen, (1983) TC Memo 1983-1, PH TCM ¶83001, 45 CCH TCM 440.

Peterson, Alan, (1991) TC Memo 1991-399, TC Memo ¶91399, 62 CCH TCM 493; Utz, Michael v. Com., (1991) TC Memo 1991-468, TC Memo ¶91468, 62 CCH TCM 813, affd (1993, CA11) 988 F2d 1217 .

Huntington, Floyd, (1982) TC Memo 1982-227, PH TCM ¶82227, 43 CCH TCM 1223.

Hebrank, Steve, (1982) TC Memo 1982-496, PH TCM ¶82496, 44 CCH TCM 978.

Dudley, Marci, (1982) TC Memo 1982-462, PH TCM ¶82462, 44 CCH TCM 763.

Stuckey, Norman, (1982) TC Memo 1982-537, PH TCM ¶82537, 44 CCH TCM 1148. St. Augustine Trawlers Inc, (1992) TC Memo 1992-148, TC Memo ¶92148, 63 CCH TCM 2362, affd sub nom Velton O'Neal v. Com., (1994, CA11) 73 AFTR 2d 94-1926, 20 F3d 1174.