Eloise Gaddy Joens - Page 27

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            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.                          





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