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fraudulent intent to conceal the income. We disagree. There is
ample evidence in the record that petitioner did in fact make
attempts to conceal his interest income. Question 10 on Schedule
B of petitioners' tax returns for the years in issue asks: “At
any time during the tax year, did you have an interest in or a
signature or other authority over a financial account in a
foreign country (such as a bank account, securities account, or
other financial account)?” For the years 1986 and 1987,
petitioner answered this question in the negative. For the years
1988 and 1989, petitioner answered yes to this question but only
listed a bank account in Israel. In signing the returns,
petitioner represented, under penalty of perjury, that he
examined the schedules accompanying the returns and that they
were “true, correct, and complete” to the best of his knowledge.
His answers to this question indicate an attempt to conceal his
foreign accounts which is a strong indication of fraud.
e. Intent To Mislead
False and inconsistent statements to respondent's agents
during the course of their investigation indicate fraudulent
intent. Grosshandler v. Commissioner, 75 T.C. 1, 20 (1980).
Petitioner failed to mention any Canadian bank accounts when
questioned about foreign accounts and when specifically
questioned about Canadian accounts only mentioned that he thought
that he had a Canadian account, but that the money was his
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