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here, however, is not simply a case involving a taxpayer's
misunderstanding of the tax law; rather, it involves a tax
evasion scheme that spans a multi-year period during which
petitioner consistently and substantially understated his income.
Petitioner advances a dubious argument that is more likely a
belated and convenient fabrication designed to facilitate his
evasion scheme than a sincere claim of naivete. Coupling the
consistent pattern of substantial underreporting with the
previously discussed circumstances, all of which indicate an
intent to conceal income, justifies the inference of fraud.
Holland v. United States, 348 U.S. at 137. Accordingly, we
conclude that respondent has shown, by clear and convincing
evidence, that petitioner has underpaid his taxes for each
taxable year at issue, except 1985 and 1986, and that some part
of each underpayment was due to petitioner's intent to conceal,
mislead, or otherwise prevent the collection of such taxes. See
Parks v. Commissioner, 94 T.C. at 660-661. Hence, as to each
taxable year at issue, except 1985 and 1986, we resolve this
issue in respondent's favor. As to taxable years 1985 and 1986,
we resolve this issue in favor of petitioner.
8. Other Matters
Petitioner objects to the introduction into evidence of his
plea agreement, contending that it lacks relevancy and fosters a
prejudicial inference. Although petitioner's conviction for
willful falsification under section 7206(1) is not dispositive on
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