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concealment of assets; (6) failure to cooperate with tax
authorities; (7) failure to make estimated tax payments; (8)
dealing in cash; (9) engaging in illegal activity; and (10)
attempting to conceal an illegal activity. Clayton v.
Commissioner, 102 T.C. 632, 647 (1994). These badges of fraud
are nonexclusive. Miller v. Commissioner, 94 T.C. 316, 334
(1990).
In light of the record, taken as a whole and by reasonable
inferences therefrom, we find that the facts show by clear and
convincing evidence that petitioner intended to evade taxes known
to be owing by conduct intended to conceal, mislead, or otherwise
prevent the collection of taxes.
The consistent understatement of large amounts of income for
a number of years is evidence of willful intent to evade.
Holland v. United States, 348 U.S. 121, 139 (1954); Rogers v.
Commissioner, 111 F.2d 987, 989 (6th Cir. 1940), affg. 38 B.T.A.
16 (1938); Conforte v. Commissioner, 74 T.C. 1160, 1201 (1980),
affd. in part and revd. on another issue 692 F.2d 587 (9th Cir.
1982); Otsuki v. Commissioner, supra at 107-108. We are mindful
that fraud cannot be inferred from a mere inadvertent
understatement of income. Holland v. United States, supra.
Petitioner is an intelligent and financially astute individual.
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