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lack of an intent to evade taxes. We find petitioners' argument
unpersuasive. In the instant case, petitioners' understatements
are both consistent and substantial; they are evidence of fraud.
c. Failure to Maintain Adequate Books and Records
Failure to maintain adequate books and records of income may
be indicative of fraud. Truesdell v. Commissioner, 89 T.C. 1280,
1302 (1987); Gajewski v. Commissioner, 67 T.C. at 200.
Respondent showed at trial that accurate records of cash receipts
for petitioner's medical practice were not maintained.
Respondent contends that this along with other evidence shows
that petitioner “skimmed” profits from his medical practice.
Respondent has not convinced us that any fraud was committed by
petitioner's professional corporation or by petitioner regarding
the profits from that corporation; we will not, therefore, base a
finding of fraud on the evidence regarding “skimming” presented
in that regard.
d. Attempts to Conceal Activities
Petitioners contend that the principal point in their favor
is that they did not attempt to conceal their assets. They argue
that if petitioners' returns for the years in issue had been
audited it would have been obvious that assets were unaccounted
for and the whereabouts of those assets would have been easy to
determine. Petitioners therefore argue that because the assets
and income were readily discoverable there could not have been a
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