- 27 -                                         
             Portillo v. Commissioner, 932 F.2d 1128 (5th Cir. 1991),                 
             affg. in part and revg. in part T.C. Memo. 1990-68;                      
             Petzoldt v. Commissioner, 92 T.C. 661 (1989); and Tokarski               
             v. Commissioner, 87 T.C. 74 (1986).  Petitioners                         
             acknowledge that there is evidence linking the unreported                
             income to Beaufort Leaf, such as the fact that each of the               
             undeposited checks for 1991 was made payable to Beaufort                 
             Leaf.  Nevertheless, petitioners argue that such evidence                
             is not sufficient to satisfy respondent's burden of proof                
             under the cases cited above.  According to petitioners,                  
             respondent must introduce "significantly more compelling                 
             evidence, such as proof that the Petitioners received the                
             proceeds of Robert's [sic] over-quota transactions."                     
                  At the outset, we note that there is evidence that,                 
             during the years in issue, Mr. Roberts joined a group                    
             of persons headed by Mr. James V. Wells to engage in a                   
             fraudulent scheme to acquire and sell excess-quota tobacco.              
             In paragraph 5(d) of both petitions, petitioners describe                
             the scheme as a widespread scheme, involving Mr. Roberts                 
             and "numerous other bogus dealers and/or legitimate                      
             dealers".  Paragraph 5(d) of the subject petitions states                
             as follows:                                                              
                       In 1990 and 1991, the managing partner                         
                  entered into an illegal scheme to fraudulently                      
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