- 25 - 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 onPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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