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In addition to the consistent pattern of substantial
understatements, petitioner, being the partner responsible for
managing the financial affairs of the partnership, did not
maintain adequate records documenting such financial affairs.
Additionally, although Fruitland operated almost exclusively on a
cash basis, petitioner frequently transacted business without
using the partnership's cash register. The failure to maintain
addequate financial records is an additional indicium of fraud.
See Bragg v. Commissioner, supra.
Petitioner routinely used large sums of cash to purchase
cashier's checks, often within days of each other, in amounts
slightly less than $10,000. Petitioner's self-serving testimony
concerning his unfamiliarity with the Federal currency
transaction reporting requirements lacks credibility. Moreover,
we give little credence to petitioner's testimony pertaining to
his aversion to financial institutions. Such explanations are
implausible. In a manner virtually undetectable by anyone
concerned, petitioner kept large sums of money in the form of
non-interest-bearing instruments for an extended period of time.
These circumstances suggest that petitioner's behavior was
motivated not by an aversion to financial institutions, but
rather an intent to conceal the existence of the money
represented by the cashier's checks. Providing implausable
explanations, dealing in large amounts of cash, and the
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