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father's. By 1989 and prior to this interview, petitioner had in
excess of $3 million in Canadian bank accounts. His explanation
could only be seen as an attempt to mislead the agents and
frustrate their investigation. We find that petitioner intended
to mislead special agents during their investigation, and this
indicates fraud.
f. Filing False Documents
This factor supports a finding of fraud for the same reasons
discussed in subsection (d) of this Opinion. Petitioner's
attempt to argue that he was misinformed about the taxability of
the interest is not persuasive. Petitioner told special agents
that he was told by an unnamed bank official that the interest
was not taxable until withdrawn, yet petitioner could not name
the official or the bank. An official from the Royal Bank of
Canada testified that it is not the policy of the bank to advise
clients on the taxability of interest in the United States. We
find that petitioner intentionally withheld information regarding
his foreign bank accounts from his accountant in an attempt to
evade taxes. This is strong evidence of fraud. See Korecky v.
Commissioner, T.C. Memo. 1985-63, affd. 781 F.2d 1566, 1569 (11th
Cir. 1986).
g. Other Factors
We also consider it significant that petitioner pleaded
guilty to violation of section 7203 for the 1987 tax year for
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