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uncle is unsupported by corroborating evidence and not worthy of
belief.
"[C]oncealment of assets or covering up sources of income,
handling one's affairs to avoid making the records usual in
transactions of the kind, and any conduct, the likely effect of
which would be to mislead or conceal" constitute a willful
attempt to evade tax. Spies v. United States, 317 U.S. 492, 499
(1943). Accordingly, respondent has proven by clear and
convincing evidence that petitioner is liable for the penalty for
fraud, and petitioner has not proven that any part of the
underpayment is not attributable to fraud.
Respondent also determined a deficiency with respect to the
$26,115 that petitioner earned in wages in 1990. Petitioner
offered no proof at trial to disprove respondent's determination.
Accordingly, petitioner has failed to prove respondent's
determinations erroneous with respect to the $26,115 that he
earned in wages in 1990.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011