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issue, particularly during the years for which respondent
determined fraud. For example, travel and entertainment expenses
were overstated by $19,913.37 in 1973, $75,284.40 in 1974,
$77,315.01 in 1975, and $20,000 in 1976. In addition, for some
of the years there were overstatements of some commission
expenses, consulting fees, legal and professional fees, salaries
and wages, interest expenses, depreciation, and rental expenses.
4. Failure to Maintain Adequate Books and Records
Failure to maintain adequate books and records of income
generally and failure to keep records of income diverted and
unreported are both indicative of fraud. Truesdell v.
Commissioner, 89 T.C. 1280, 1302 (1987); Gajewski v.
Commissioner, 67 T.C. at 200.
The record contains evidence showing that petitioner's books
and records with respect to income and expenses were inadequate,
incomplete, and sometimes misleading. Substantial income was
unreported and claimed expenses were overstated or not
substantiated.
5. Concealment of Income or Assets
The concealment of income or assets is an indicium of fraud.
Bradford v. Commissioner, 796 F.2d at 307-308.
Petitioner handled the transactions involving Lockheed and
Ashland to conceal from respondent the large sums of money paid
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