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harbor proceeds from income producing activities. As noted
above, petitioner partially repaid loans from Sotheby's with
substantial amounts disbursed from the Ivory Land account.
Petitioner also used funds from the Ivory Land account to buy
various art pieces from Christie's. Like the Pierpont Account,
we think petitioner used her corporate nominees to conceal
assets.
Further evidence of asset concealment is the fact that
petitioner deposited proceeds from horse sales into an account
belonging to petitioner's broker and trainer, Margie Goldstein,
once again making it difficult for respondent to trace these
proceeds to petitioner.
Petitioner argues that her entire course of conduct fails to
demonstrate that the deficiencies were due to an intent to evade
taxes, citing Stoltzfus v. United States, 398 F.2d 1002 (3d Cir.
1968), and Nelon v. Commissioner, T.C. Memo. 1997-49, for
support. Instead of supporting petitioner's position, Stoltzfus
v. United States, supra, reinforces respondent's position. In
that case, the Court affirmed the judgment of the District Court
denying the taxpayer's request for a refund of civil fraud
penalties imposed pursuant to section 6653(b) of the 1954 Code.
The taxpayer had failed to file returns from 1943 through 1958.
Like petitioner, the taxpayer had extensive business experience,
a keen awareness of financial matters and was aware of his duty
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