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f. Implausible or Inconsistent Explanations of Behavior
Petitioner maintains that he did not intend to fraudulently
understate his income for 1987 and 1988. His actions, however,
are consistent with those of a person possessing the intent to
defraud. For example, petitioner asserts that he gave Mr. Bruno
net income figures for his medical practice and that Mr. Bruno
made a mistake by placing net income on the gross income line of
Schedule C. This assertion is factually implausible and
unsupported by the evidence. Mr. Bruno repeatedly testified, and
we think truthfully so, that the income figures given to him by
petitioner for 1987 and 1988 were the amounts of petitioner's
total gross income for each year. Petitioner not only failed to
tell Mr. Bruno there was a mistake on the gross income line of
the Schedule C, but he also never mentioned this error to Ms.
Davis during the civil examination. Consequently, it is
difficult to believe that petitioner could have failed to notice
that the total amount of the checks he received from personal
injury attorneys so greatly exceeded his reported gross income.
The more plausible explanation of his alleged discovery of this
so-called mistake, however, is that there was no mistake. It was
merely petitioner's explanation designed to shift the culpability
and blame away from himself.
As further support for his reliance argument, petitioner
emphasized that he knew nothing about taxes, recordkeeping, or
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