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v. Commissioner, 440 F.2d 688, 689 (9th Cir. 1971), affg. per
curiam T.C. Memo. 1969-159; Niedringhaus v. Commissioner, supra
at 212. Petitioner's testimony was unreasonable, improbable, and
questionable, and we do not accept it.
The sophistication, education, and intelligence of the
taxpayer are also relevant. Halle v. Commissioner, 175 F.2d 500,
503 (2d Cir. 1949), affg. 7 T.C. 245 (1946); Niedringhaus v.
Commissioner, supra. Although petitioner is not highly educated,
he held himself out as a financial and business expert. He kept
books and prepared individual, corporate, and partnership tax
returns. He purported to set up trusts, corporations, and
partnerships. He prepared Forms W-2 (at least, his own), and
held himself out as the person with whom the revenue agent should
deal in conducting the Wayanne audit. In testifying, he referred
more than once to the gift tax limitation of $10,000 per year.
We believe he was informed about taxes, and intended to evade
them.
We have no doubt that petitioner intended to conceal his
assets. The use of multiple entities with names and EIN's, use
of his son's Social Security number on the Ferry Associates
account (before stating for two consecutive years in issue that
the children's numbers were "applied for"), putting his house,
automobile, and telephone in other names, and the various other
devices employed by petitioner convince us that he intended to
conceal his assets.
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