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Bellamy was given an opportunity to review photocopies of the 1984,
1985, and 1986 brown books, which were provided to her through
petitioners' counsel. We conclude that petitioner did not turn the
brown books over to Ms. Bellamy as asserted, and that he intended
to mislead Ms. Bellamy by withholding this information.
(5) Lack of Credibility of Petitioner's Testimony
A taxpayer's lack of credibility, inconsistent testimony, or
evasiveness are factors in considering the fraud issue. Toussaint
v. Commissioner, 743 F.2d 309, 312 (5th Cir. 1984), affg. T.C.
Memo. 1984-25. Portions of petitioner's testimony were not
credible. For example, petitioner accused Ms. Bellamy of
manufacturing a portion of his 1985 First American bank loan
application. Furthermore, he testified that Ms. Bellamy did not
adequately inform petitioners about the statute of limitations
extension period, and that she lied about her handling of the brown
books. We disbelieve petitioner's accusations.
(6) Failure to Cooperate with Tax Authorities
A failure to cooperate with tax authorities is further proof
of fraud. Rowlee v. Commissioner, 80 T.C. 1111, 1125 (1983).
Petitioner admitted that he was not cooperative with Ms. Bellamy
during one of their audit meetings, and that he once held a grudge
against the IRS. At the second audit meeting, in which a special
agent accompanied Ms. Bellamy to petitioners' home, petitioner
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