- 29 -
Although not dispositive, petitioner's convictions under
section 7206(1) are probative evidence that he intended to evade
his taxes. See Wright v. Commissioner, 84 T.C. 636, 643-644
(1985).
7. Other Factors
A taxpayer's practice of regularly depositing large portions
of his business receipts from his sole proprietorship into his
personal bank accounts may be evidence of fraud. See Farber v.
Commissioner, 43 T.C. 407 (1965), supplemented by 44 T.C. 408
(1965). During the years in issue, petitioner regularly
deposited large amounts of receipts from his medical practice
(whether it was a sole proprietorship or a corporation) into his
personal bank accounts; e.g., the AT #4 account, the AT #9
account, and the Society National Bank account. Petitioner made
these deposits in an attempt to conceal his income. This is
evidence of fraud.
C. Conclusion
After reviewing all of the facts and circumstances, we
conclude that respondent has clearly and convincingly proven
that all of the underpayments of tax resulting from petitioner's
unreported medical practice income and rental income for each of
the years in issue were due to fraud on the part of petitioner.
Therefore, we sustain respondent's determination that petitioner
is liable for additions to tax for fraud pursuant to section
6653(b) for 1985, 1986, 1987, and 1988.
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