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include: (1) Understating income, (2) maintaining inadequate
records, (3) failing to file tax returns, (4) having implausible
or inconsistent explanations of behavior, (5) concealing assets,
(6) failing to cooperate with tax authorities, (7) engaging in
illegal activity, (7) creating false documents or records, (8)
dealing in cash, and (9) overstating deductions.
See Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th Cir.
1986) affg. T.C. Memo. 1984-601; Meier v. Commissioner, 91 T.C.
273, 297-298 (1988); Estate of Temple v. Commissioner, 67 T.C.
143, 161 (1976).
Petitioner's deemed admissions contain numerous indicia of
her fraudulent intent to evade taxation with respect to each of
the taxable years in issue. For example, the facts deemed
admitted establish the following:
Paragraph 26. Petitioner's failure to maintain
complete and accurate records of her income-producing
activities and her failure to produce complete and
accurate records to the respondent in connection with
the examination of petitioner's income tax returns for
taxable years 1987 and 1988 was fraudulent with the
intent to evade tax.
Paragraph 32. For both 1987 and * * * 1988,
petitioner fraudulently and with intent to evade tax
deducted personal items as business expenses, deducted
items she could not substantiate and claimed expenses
that were not ordinary and necessary business expenses
pursuant to section 162.
Paragraph 33. During 1987 and 1988, the petitioner
engaged in a pattern of conduct which demonstrates
that she intentionally and knowingly failed to report
substantial income in both years.
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