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Commissioner, 89 T.C. 1280, 1302 (1987). In addition,
Mr. London supplied inaccurate information to Mr. Trugman,
an accountant who prepared the Schedules C for M.L.
Associates. Mr. Trugman testified that he was not able
to track all the deposits made into accounts for M.L.
Associates. Providing incorrect information to a tax
return preparer is also a badge of fraud. Estate of
Temple v. Commissioner, 67 T.C. 143, 162-163 (1976).
Upon consideration of the entire record, we find that
respondent has proven by clear and convincing evidence that
Mr. London acted with the requisite fraudulent intent, and
that the entire understatement of tax for 1983 and 1985
is due to Mr. London's fraud, as determined by respondent.
Accordingly, we sustain respondent's determination that
Mr. London is liable for the additions to tax for fraud
under section 6653(b)(1) and (2).
We reach a different conclusion with respect to
Mrs. London. In her case, we do not believe that
respondent has proven by clear and convincing evidence that
she intended to evade tax believed to be owing by conduct
intended to conceal, mislead, or otherwise prevent the
collection of such tax. See Recklitis v. Commissioner,
91 T.C. at 909; Rowlee v. Commissioner, 80 T.C. at 1123.
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