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each petitioner was in material respects implausible; (6) the
testimony of each petitioner was questionable, contradicted by
other evidence in the record, and lacked credibility in certain
material respects; and (7) petitioners failed to cooperate with
respondent's representatives in that, inter alia, (a) they failed
to provide information that Mr. Kaply had requested at the
September 1989 meeting with respect to certain bank accounts,
and, approximately one month later, Mr. Kaply had to summons that
information, (b) they incorrectly told Mr. Kaply at the September
1989 meeting that all of the deposits made into the Indian Head
business savings account were transferred from the Indian Head
business checking account, and (c) they did not disclose the
existence of the Seabrook Properties account at the September
1989 meeting.
Based on our examination of the entire record before us, we
find that respondent has established by clear and convincing
evidence that petitioners intended to evade tax for each of the
years 1986 and 1988 that they knew to be owing by conduct in-
tended to conceal, mislead, or otherwise prevent the collection
of such taxes.
Petitioners contend, as they did with respect to 1987, in a
conclusory manner and with no support in the record that assuming
arguendo that the Court were to find fraudulent intent for 1986
and 1988, the respective portions of the 1986 underpayment and
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