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referenced real estate purchases and the creation of the
investment account were among the documents that she signed
without reading. Petitioner also explains that the absence of
unusual or lavish expenditures is apparent from the fact that her
children attended public schools and that she did not make any
substantial expenditures herself.
We are not persuaded by petitioner's assertions in this
regard. Because her testimony is self-serving and lacks
credibility, we decline to accept it. Accordingly, we conclude
that this factor favors respondent.
The fourth factor we consider is whether Mr. Goings was
forthright about the omitted income. Petitioner has not
established that Mr. Goings was evasive concerning his true level
of income. It is obvious from the record that Mr. Goings did not
attempt to conceal the kickback income from petitioner. Indeed,
quite the contrary is true. Mr. Goings deposited approximately
83 percent, or $870,767, of the kickback income into the couple's
joint accounts. Nearly 11 percent of the kickback income was
deposited into an account managed by petitioner. In contrast,
less than 10 percent of the kickback income was deposited in Mr.
Goings's exclusive account. Although making deposits into an
exclusive account may indicate evasive intent, we hesitate to
conclude that Mr. Goings possessed such intent in light of the
amount of funds he deposited into the couple's joint accounts.
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