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scrutiny of the taxpayer's finances; and (4) failure to make
estimated tax payments. Id. at 308.
In the instant case, we find the following indicia of fraud:
(1) Petitioner admitted that he did not file Federal income tax
returns for the taxable years 1982 through 1994; (2) petitioner
did not maintain records for the years at issue; (3) petitioner
concealed assets by depositing cash in 10 safe deposit boxes in
two states, and registering his Cadillac in a different name; (4)
petitioner engaged in illegal business activities; (5) petitioner
attempted to conceal his illegal business activities by
concealing assets and using false identifications; (6) petitioner
had substantial dealings in cash, including paying most of his
bills during the years at issue with cash, cashier's checks, and
money orders; (7) petitioner did not make estimated tax payments;
and (8) petitioner's explanation of the source of the unreported
income is implausible.
Upon consideration of all of the facts and circumstance of
this case, we hold that respondent has carried his burden of
proving petitioner's fraudulent intent with respect to the
underpayments for the years at issue by clear and convincing
evidence.
Issue 3. Whether Petitioner Is Liable for Self-Employment Tax
Respondent determined that petitioner is liable for self-
employment tax of $5,387 and $5,859 in 1987 and 1988,
respectively. Petitioner asserts that he had no income subject
to self-employment tax during the years at issue.
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