Steven J. Romer - Page 21

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               Strong evidence of petitioner's fraudulent intent for each             
          year in issue exists in this case.  Petitioner was an experienced           
          attorney.  Petitioner certainly knew of his professional                    
          obligation to maintain client funds and investments separate from           
          his own funds and investments.  With the exception of the                   
          $450,000 obtained by petitioner as a loan from William Marion,              
          petitioner received substantial income by embezzling funds from             
          his clients, by kiting checks, and by forging signatures, none of           
          which petitioner reported on his Federal income tax returns.                
               Petitioner failed to file Federal income tax returns for               
          many years, and petitioner's Federal income tax returns for 1988            
          and 1989 were untimely filed only after petitioner was contacted            
          by respondent's representative about the delinquent returns.                
               Petitioner's Federal income tax returns for 1988, 1989, and            
          1990 that were eventually filed were inaccurate and failed to               
          report significant income that petitioner received in each year.            
               Petitioner's pattern of not reporting taxable income, along            
          with the other factors mentioned, establish by clear and                    
          convincing evidence petitioner's fraud with regard to his Federal           
          income taxes for 1988, 1989, and 1990.  Holland v. United States,           
          348 U.S. 121, 137 (1954); Bradford v. Commissioner, 796 F.2d 303            
          (9th Cir. 1986), affg. T.C. Memo. 1984-601.                                 
               Further, petitioner has not satisfied his burden of proving            
          herein that any of the income adjustments that we have sustained            
          were not attributable to fraud.  Accordingly, the 75-percent                

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