- 20 - 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 reportedPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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