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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
investment.
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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