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to conceal the illegal activity which produced that income.
See Patton v. Commissioner, 799 F.2d 166, 171 (5th Cir.
1986), affg. T.C. Memo. 1985-148. Moreover, petitioner has
not shown that he maintained adequate books and records
regarding his involvement in the illegal activity. His
failure to maintain adequate books and records is
indicative of fraud. See Truesdell v. Commissioner, 89
T.C. 1280, 1302 (1987); Gajewski v. Commissioner, supra
at 200. The fact that petitioner dealt in large amounts
of cash and his failure to inform his return preparer
of his illegal income also evidence fraud. See Estate
of Mazzoni v. Commissioner, 451 F.2d 197, 202 (3d Cir.
1971), affg. T.C. Memo. 1970-37. We also find that
petitioner's lack of credibility, his inconsistent
testimony regarding the marijuana smuggling activity,
and his general evasiveness evidence fraudulent intent.
See Bradford v. Commissioner, supra at 307; Toussaint v.
Commissioner, 743 F.2d 309, 312 (5th Cir. 1984), affg. T.C.
Memo. 1984-25; Welker v. Commissioner, T.C. Memo. 1997-472.
In addition, petitioner instructed Mr. Nelson to deposit
the proceeds of the illegal activity in bank accounts in
amounts of less than $10,000 each for the purpose of
concealing such deposits from respondent. See Parks
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