J.J. Zand - Page 196

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          to conceal, may justify a strong inference of fraud.  Parks v.              
          Commissioner, 94 T.C. 654, 664 (1990).                                      
               Over the years, courts have developed a nonexclusive list of           
          factors that demonstrate fraudulent intent.  These "badges of               
          fraud" include:  (1) Understating income, (2) maintaining                   
          inadequate records, (3) failing to file tax returns, (4)                    
          implausible or inconsistent explanations of behavior, (5)                   
          concealment of income or assets, (6) failing to cooperate with              
          tax authorities, (7) attempting to conceal illegal activities,              
          (8) failing to make estimated tax payments, and (9) filing false            
          documents.  See Douge v. Commissioner, 899 F.2d 164, 168 (2d Cir.           
          1990); Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th Cir.            
          1986), affg. T.C. Memo. 1984-601.  Several of these indicia of              
          fraud are present herein.                                                   
               1.  Petitioner's Sophistication and Experience                         
               The sophistication and experience of a taxpayer are relevant           
          in determining whether fraud exists.  Stephenson v. Commissioner,           
          supra at 1006.  Petitioner was a highly intelligent, astute, and            
          successful businessman.  He was a consummate salesman.  He dealt            
          frequently with executives of major corporations and prominent              
          Iranian officials.  He was a strong negotiator.  He was                     
          thoroughly familiar with his vast business operations, and he               
          controlled them.  Consequently, it is unlikely that he would not            
          have realized that his Federal income tax liabilities were                  





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