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and for 1989. For 1988, the understatement of $2,607 may, in
isolation, not be regarded as substantial, but it does constitute
an understatement, and taken together with those of the other
years it reflects a pattern of understatement for all of the
years.3
With regard to fraudulent intent, the evidence establishes
for each year in issue that petitioner realized significant
income that he failed to report, that petitioner failed to pay
significant tax liabilities, that petitioner failed to maintain
adequate books and records, that petitioner failed to file income
tax returns, and that petitioner did not cooperate with
respondent. Petitioner attempted to conceal assets and bank
accounts, and petitioner misled respondent's agents. Petitioner
did not file Federal income tax returns for the years in issue
during which he realized substantial income.
We conclude that for each of the years in issue respondent
has proven by clear and convincing evidence that petitioner
fraudulently intended to evade his correct Federal income tax
liabilities.
3 As explained supra p. 15, to the extent respondent has not
credited against total unexplained bank deposits charged as
income to petitioner the specific items of income that we charge
to petitioner under the specific item method of proof,
petitioner, in the Rule 155 computation, is to be given credit
therefor, and adjustments to the above calculations will
be necessary and may affect the amount of the understatements for
each year.
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