Leonard Ray Blanton and Betty Blanton - Page 20

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            Congressman.  Winning eleven of thirteen campaigns for office,                              
            his political career culminated in his election to the highest                              
            political office in the State.  As Governor, petitioner was                                 
            responsible for running the State and supervising 38,000                                    
            employees.  Petitioner cannot claim ignorance with respect to the                           
            value of the oil partnership.  Petitioner was a sophisticated                               
            investor who knew, and even admitted, that he made a bad                                    
                  Finally, the following factors are indicative of                                      
            petitioner's fraudulent intent: (1) Petitioner's substantial                                
            understatement of income coupled with circumstances showing an                              
            intent to conceal; see Holland v. United States, 348 U.S. 121                               
            (1954); (2) petitioner's involvement in illegal activities and                              
            his attempts to conceal those illegal activities; see Bradford v.                           
            Commissioner, supra; (3) petitioner's act of filing false                                   
            documents and failing to comply with known reporting                                        
            requirements; see Stephenson v. Commissioner, 79 T.C. 995, 1007                             
            (1982), affd. 748 F.2d 331 (6th Cir. 1984); and (4) petitioner's                            
            making false and misleading statements to respondent's agents;                              
            see Grosshandler v. Commissioner, 75 T.C. 1, 20 (1980).                                     
                  In light of the foregoing, we find that respondent has                                
            proven by clear and convincing evidence that petitioner engaged                             
            in conduct intended to conceal, mislead, or otherwise prevent the                           
            collection of his 1978 taxes.  Petitioner fraudulently reported                             

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