- 27 - and various assets used in the drug trafficking operation were held by corporations in order to conceal ownership. Extensive dealing in large amounts of cash also constitutes evidence of fraud. Estate of Mazzoni v. Commissioner, supra. Various assets used in the drug trafficking operation were paid for in full, and petitioner's $250,000 home was paid for in cash. On occasion, petitioner would also "pay-out" other members of the smuggling operation in cash. After scrutinizing the above-mentioned factors, in combination with the testimony of Sydoriak, we conclude that the record contains clear and convincing evidence of petitioner's intent to conceal, mislead, or otherwise prevent the collection of taxes on the unreported income for the years in issue. We hold that the understatements of tax attributable to the unreported income were due to fraud. Accordingly, we sustain respondent's determination that petitioner is liable for additions to tax for fraud. Issue 3. Addition to Tax for Substantial Understatement Respondent determined that petitioner is liable for additions to tax for substantial understatement under section 6661 for the years in issue. Petitioner asserts that she is entitled to innocent spouse status and therefore not liable for the addition to tax for substantial understatement. We have found that petitioner is not entitled to innocent spouse status.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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