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provided on which estimates of additional business expenses could
be made.
Petitioners’ claim that the large personal investments and
purchases were made with accumulated, nontaxable capital savings
from earlier years is completely unsubstantiated and incredible.
Petitioners’ investments in the bearer bonds and other large
personal expenses that were incurred during the years in issue
appear clearly to have been paid with payments from unreported
sales of Cal Ben deposited into the Lloyds/Sanwa account.
Instead of presenting credible evidence (e.g., receipts,
invoices, and testimony of payees identified on checks
representing alleged additional business expenses), petitioners
largely offered only speculative testimony and general survey
data.
The credible evidence before us establishes that
petitioner's 50-percent share of the cumulative unreported gross
sales of Cal Ben is approximately $960,000. See chart supra p.
7. It is established that substantial underpayments of
petitioners' correct Federal income tax liabilities occurred for
each year in issue.
Because of his criminal conviction for tax evasion,
petitioner's fraudulent intent with regard to his 1986 Federal
income tax liability is established. DiLeo v. Commissioner, 96
T.C. at 885-886; Amos v. Commissioner, 43 T.C. 50 (1964), affd.
360 F.2d 358 (4th Cir. 1965).
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