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authorities; see McCullough v. Commissioner, T.C. Memo. 1993-70;
(4) failure to produce records during discovery, see Scallen v.
Commissioner, 877 F.2d 1364, 1370 (8th Cir. 1989), affg. T.C.
Memo. 1987-412; (5) destruction of records, see Estate of Beck v.
Commissioner, 56 T.C. 297 (1971); (6) misleading statements or
actions, see McManus v. Commissioner, T.C. Memo. 1972-200, affd.
without published opinion 486 F.2d 1399 (4th Cir. 1973), (7)
commingling of personal assets with those of the taxpayer's
corporation in an attempt to avoid tax, see United States v.
Walton, 909 F.2d 915 (6th Cir 1990); (8) diversion of income to
third parties, see Lewis v. Commissioner, T.C. Memo. 1983-547;
(9) reporting income from property beneficially owned by the
taxpayer on the returns of family members, see Lang v.
Commissioner, T.C. Memo. 1961-134; (10) structuring of a business
and use of cash management techniques which made difficult the
tracing of income, see Scallen v. Commissioner, supra at 1370-
1371; (11) banking devices used to conceal earnings, see Maddas
v. Commissioner, 114 F.2d 548 (3d Cir. 1940), affg. 40 B.T.A. 572
(1939); (12) concealing income under the names of other persons
who reported such income, see Hecht v. Commissioner, 16 T.C. 981
(1951); and (13) omission of income from the taxpayer's property,
title to which was held in names of others who reported the
income therefrom, see Furnish v. Commissioner, 262 F.2d 727 (9th
Cir. 1958). In addition, the taxpayer's educational background
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