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for each of Kenmore’s fiscal 1981 and fiscal 1982, and (2) Gleave
did not deposit into Kenmore’s Account the proceeds he claims to
have received from his grandmother’s estate.
Also, petitioners have tried to throw up smokescreens by
general contentions that Broskin’s dealings would fill this gap.
But, as we have shown, Broskin’s dealings would not have affected
the substantial shortfall in Kenmore’s reporting of its taxable
income.
Petitioners have tried to explain away Kenmore’s failure to
keep sufficient records of currency by arguing that Kenmore’s
need for currency (e.g., in order to cash checks) explains the
gap in its reporting. We have no reason to believe the
underlying factual predicates. As far as we can tell, any check-
cashing that Kenmore may have done probably was small in amount
and affected only the check-versus-currency mix (and not the
total amount) of the deposits to Kenmore’s Account.
The transparent falseness of petitioners’ explanation of
Kenmore’s reporting omissions is itself an indicator of Kenmore’s
fraudulent intent. Bahoric v. Commissioner, 363 F.2d at 153-154;
Boyett v. Commissioner, 204 F.2d at 208.
We conclude from the foregoing, and we have found, that
respondent has shown by clear and convincing evidence that
Kenmore intended to evade its income taxes for each of its fiscal
1981 and fiscal 1982 years, which taxes Kenmore knew or believed
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