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assets, and extensive dealings in cash support an inference of
fraud. Spies v. United States, supra at 499; Parks v.
Commissioner, 94 T.C. 654, 664-665 (1990) (purchase of cashier's
checks to avoid filing of Currency Transaction Reports).
Beginning in 1982, petitioner opened 10 separate checking and
savings accounts. Then, in a series of transactions, petitioner,
among other things, converted over $800,000 in investor funds
into cashier's checks made payable to himself in order to avoid
creating a transactional record in the corporate accounts.
Respondent has established, through petitioner's deemed
admissions, that petitioner's objective was to defraud the United
States by conducting the financial and banking activities of the
investment scheme in a manner that was not readily traceable.
And finally, in addition to the various indicia of fraud
that are present, we consider as evidence of fraud petitioner's
conviction under section 7206(1) for filing a false income tax
return. In Wright v. Commissioner, 84 T.C. 636, 643 (1985), this
Court concluded that a prior conviction under section 7206(1)
does not collaterally estop a petitioner from contesting a fraud
determination under section 6653(b). However, a conviction for
willful falsification, while not dispositive, is evidence of
fraud. Id. at 643-644. On January 14, 1991, petitioner was
found guilty under section 7206(1) on two counts of filing false
income tax returns for 1984 and 1985.
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