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Commissioner, 91 T.C. 874, 910 (1988). This list is
nonexclusive. Miller v. Commissioner, 94 T.C. 316, 334 (1990).
During the years in issue, petitioner failed to file valid
tax returns and failed to report substantial amounts of income
from his veterinary practice. Petitioner intentionally did not
maintain records of his income or business expenses and
intentionally discarded the minimal records that he received.
The $65,000 amount, although stipulated in this case, cannot be
shown to be the actual amount of income earned in petitioner's
veterinary practice. Moreover, petitioner did not cooperate with
respondent during the administrative or judicial phases of this
case. Petitioner refused to meet with respondent's agent and
responded to requests for meetings with tax protester rhetoric.
Petitioner submitted numerous correspondence to respondent that
attempted to advance his tax protester position and did not
address the factual accuracy of respondent's determination.
During testimony at trial, petitioner admitted that he was aware
that the Tax Court has held the tax protester arguments to be
frivolous.
Petitioner took affirmative steps to conceal his income and
assets. From 1987 until 1991, petitioner substantially avoided
use of commercial banks for depositing income and paying expenses
from his veterinary practice. Petitioner dealt extensively in
cash for payment of expenses and did not retain receipts of the
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