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obligation to file returns, (11) failing to file tax returns,
(12) failing to make estimated tax payments, and (13) dealing in
cash. See Spies v. Commissioner, supra at 499; 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; Recklitis v. Commissioner, 91 T.C. 874, 910
(1988). Although no single factor is necessarily sufficient to
establish fraud, the combination of a number of factors
constitutes persuasive evidence. Solomon v. Commissioner, 732
F.2d 1459, 1461 (6th Cir. 1984), affg. per curiam T.C. Memo.
1982-603. We note that some conduct and evidence can be
classified under more than one factor.
1. Reliance on Return Preparer
Petitioner argued that his longtime close friend Kwang Kim
prepared his return and that petitioner relied upon Mr. Kim. We
found that petitioner, and not Mr. Kim, prepared the returns.
This argument does not support petitioner.
2. Petitioner's Sophistication and Experience
Petitioner is a medical doctor who had no formal training in
accounting or tax return preparation. On the basis of these
facts, we shall not hold petitioner to either a high or low
standard while evaluating his actions.
3. Consistent and Substantial Understatements of Income
The mere failure to report income is not sufficient to
establish fraud. Merritt v. Commissioner, 301 F.2d 484, 487 (5th
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