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reported on his returns; that he ignored his attorneys' advice
concerning the proper reporting of his commissions for Federal
income tax purposes; and that he intended to conceal his receipt
of the commissions in an attempt to evade Federal income tax.
Petitioner's attempt to combat this overwhelming evidence against
him with inconsistent and false explanations is further evidence
of his fraud. The same is true with respect to petitioner's
attempt to place the blame on Finley Kumble for his tax problems.
v. Attempt to Conceal Activities
Petitioner used nominees to conceal his ownership interest
in CAI. He used a third party to withdraw substantial funds for
himself and to pay his creditors as part of a scheme to avoid
paying taxes on his earned commissions. We find both of these
actions to be indicia of fraud.
vi. Other Factors
a. Petitioner's Sophistication
A taxpayer's sophistication and experience are relevant in
determining fraudulent intent. Stephenson v. Commissioner,
79 T.C. 995, 1006 (1982), affd. 748 F.2d 331 (6th Cir. 1984).
Petitioner was a sophisticated and experienced businessman,
especially in the international arena. We find this factor to be
evidence of fraud under the facts contained herein.
b. Withholding Information From Tax Preparer
Petitioner's 1980 through 1982 returns contained many false
statements and/or failed to report relevant information. The
1980 and 1981 returns stated erroneously that petitioner did not
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