- 36 -
no single factor is necessarily sufficient to establish fraud,
the existence of several indicia constitutes persuasive
circumstantial evidence of fraud. See Bradford v. Commissioner,
supra at 307; Petzoldt v. Commissioner, supra at 700.
The record in this case is replete with indicia of fraud by
petitioners, including the following: Petitioners consistently
failed to report substantial amounts of income for the years
1992, 1993, and 1994. They gave inconsistent and implausible
explanations about the source of the bank deposits at issue. We
did not find the testimony of either Mr. Mifsud or Ms. Mifsud to
be credible in many material respects, including their testimony
that the source of the bank deposits at issue was their alleged
cash hoard. The restaurant business in which petitioners engaged
dealt primarily in cash, and most of the deposits that petition-
ers made during the years at issue were in cash.
Based on our examination of the entire record in this case,
we find that respondent has established by clear and convincing
evidence that petitioners intended to evade tax for each of the
years 1992 through 1994, which they believed to be owing, by
conduct intended to conceal, mislead, or otherwise prevent the
collection of such tax.9 We further find on that record that
9 We have considered all of the contentions and arguments
of petitioners that are not discussed herein, and we find them to
be without merit.
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