Thomas G. Roots - Page 1

                                 T.C. Memo. 1997-187                                  

                               UNITED STATES TAX COURT                                

                           THOMAS G. ROOTS, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 19287-95.                   Filed April 21, 1997.           

                    P underreported income from his rental and                        
               insurance businesses during 1984, 1985, 1986, and 1987.                
               P did not keep records for either business, and he                     
               commingled funds of each business with funds of the                    
               other and with his personal funds.  P received                         
               commission checks from his insurance business, but he                  
               reported on his tax returns only the commissions for                   
               which he received Forms 1099, Miscellaneous Income.                    
               P told rental tenants to mislead Internal Revenue                      
               Service agents as to the amount of rent they paid to                   
               him.  P was convicted of willfully attempting to evade                 
               or defeat income taxes under sec. 7201, I.R.C., for his                
               1987 taxable year and of willfully attempting to                       
               interfere with the administration of internal revenue                  
               laws in violation of sec. 7212(a), I.R.C.                              
                    Held:  The currency deposits to P's bank account                  
               for his 1984 and 1985 taxable years are taxable                        
                    Held, further, P is liable for additions to tax                   
               for fraud under sec. 6653(b)(1) and (2), I.R.C., for                   

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