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[*51]

An intent to evade tax may be inferred from "concealment of assets or covering up sources of income". , 317 U.S. at 499. Engaging in transactions likely to mislead or conceal is evidence of fraudulent intent. ;, T.C. Memo. 1999-235, slip op. at 18-19,, 238 F.3d 422 (6th Cir. 2000). A taxpayer's use of a business to conceal the personal nature of expenses is evidence of fraud. , 42 T.C. 358, 383 (1964),, 355 F.2d 929 (6th Cir. 1966); Evans v. Commissioner, T.C. Memo. 2010-199, slip op. at 13;, T.C. Memo. 2001-168, slip op. at 45-46.

During the years at issue petitioner and Mr. Hovind acquired property using funds in CSE's accounts. While some properties initially were titled in petitioner's and Mr. Hovind's names, other properties initially were titled in Mr. Hovind's name alone or in CSE's name. Petitioner and Mr. Hovind titled the properties in different names even though they used their shared funds to purchase the properties and petitioner drafted and signed checks to purchase the properties.

Through a series of transactions, petitioner and Mr. Hovind purportedly transferred the properties to the Faith Baptist Fellowship and later to various ministerial trusts. Petitioner signed many of the documents that purported to