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be inferred from a pattern of conduct. See Spies v. United
States, 317 U.S. 492, 499 (1943). Indicia of fraud may include
understated or unreported income, inadequate records and/or
intentional concealment of income and assets, and failure to
cooperate with taxing authorities. See Bradford v. Commissioner,
796 F.2d 303 (9th Cir. 1986), affg. T.C. Memo. 1984-601.
Based on the above, we hold that petitioner is liable for
the addition to tax for fraud for his 1983, 1984, 1985, 1986, and
1987 taxable years. With respect to all other matters
determined, respondent does not bear the burden of proof, and
petitioner is found to have failed properly to prosecute and
defaulted on his opportunity to show respondent’s error(s).
To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011