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(2) inadequate books and records, (3) implausible or inconsistent
explanations of behavior, (4) engaging in illegal activities, (5)
failure to cooperate with tax authorities, (6) concealing assets,
and (7) dealing in excessive amounts of cash. Bradford v.
Commissioner, 796 F.2d 303, 307-308 (9th Cir. 1986), affg. T.C.
Memo. 1984-601; Estate of Mazzoni v. Commissioner, 451 F.2d 197,
202 (3d Cir. 1971), affg. T.C. Memo. 1970-37. We consider all of
the facts and circumstances of each case to decide if fraudulent
intent is present. King's Court Mobile Home Park, Inc. v.
Commissioner, 98 T.C. 511, 516 (1992); Recklitis v. Commissioner,
91 T.C. 874, 910 (1988). Upon examination of the entire record,
we conclude that petitioner's underpayment of Federal income
taxes for 1982, 1983, and 1984 is attributable to fraud.
A pattern of consistent underreporting of income for several
years, especially when accompanied by other circumstances showing
intent to conceal, such as illegal narcotics trafficking, is
strong evidence of fraud. Holland v. United States, supra;
Patton v. Commissioner, 799 F.2d 166, 171 (5th Cir. 1986), affg.
T.C. Memo. 1985-148; Estate of Mazzoni v. Commissioner, supra;
Anderson v. Commissioner, 250 F.2d 242, 250 (5th Cir. 1957),
affg. on this issue T.C. Memo. 1956-178. Petitioner had
unreported income of $41,908 in 1982, $58,745 in 1983, and
$262,147 in 1984.
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