-13-
affd. 519 F.2d 1121 (5th Cir. 1975). This intent may be inferred
from circumstantial evidence, Powell v. Granquist, 252 F.2d at
61; Gajewski v. Commissioner, 67 T.C. 181, 200 (1976), affd.
without published opinion 578 F.2d 1383 (8th Cir. 1978),
including the implausibility of petitioner’s explanations,
Bradford v. Commissioner, 796 F.2d 303, 307 (9th Cir. 1986) (and
cases therein cited), affg. T.C. Memo. 1984-601; Boyett v.
Commissioner, 204 F.2d 205, 208 (5th Cir. 1953), affg. a
Memorandum Opinion of this Court dated Mar. 14, 1951.
A. Tax Liability
We have found that petitioner received wage income of
$23,371.94 and pension distributions of $15,720 during 1993.
Petitioner has not directed our attention to, and we have not
found, anything in the record suggesting that any part of the
pension distributions is excludable from gross income (as, for
example, investment in the contract, within the meaning of sec.
72), except for petitioner’s arguments about the status of
Federal Reserve Notes and the “Fair Market Value Exchange of his
labor”. We conclude that respondent has shown by clear and
convincing evidence that petitioner has more than $39,000 of 1993
adjusted gross income.
In the notice of deficiency, respondent allowed deductions
of $3,700 for the standard deduction and $2,350 for the personal
exemption. Petitioner has not directed our attention to, and we
have not found, anything in the record suggesting that he is
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