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5. Filing False Documents.
Fraud may also be inferred when a taxpayer files false
documents. Bradford v. Commissioner, supra. Petitioner's return
for taxable year 1984 explicitly states that he did not maintain
a foreign bank account during the taxable year. Petitioner
contends, however, that it was never his intention to make such
an express representation. Instead, petitioner claims that he
cannot explain why his Schedule B for 1984 states that he did not
maintain a foreign bank account during the taxable year.
Petitioner blames his accountant for the statement on the return,
contending that the accountant, or someone under his control, is
responsible for making it without petitioner's authority or
direction. We do not accept petitioner's argument regarding this
statement on the return. Moreover, although petitioner's
accountant testified that the statement in question might be the
result of an error on his part, we attribute little weight to his
testimony as we found it to be lacking in credibility.
6. Lack of Credibility of Taxpayer's Testimony.
A taxpayer's incredible testimony also supports an inference
of fraud. Bradford v. Commissioner, supra. We have difficulty
accepting as credible much of petitioner's testimony. For the
most part, it is self-serving and implausible.
7. Conclusion.
Petitioner primarily argues that he misunderstood the income
tax reporting requirements for foreign interest income. At issue
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