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1989, petitioners underreported substantial amounts of taxable
income (i.e., more than $50,000 each year). See Holland v.
Commissioner, 348 U.S. 121, 139 (1954) (holding that a pattern of
consistently and substantially underreporting income may justify
an inference of fraud). We also note that petitioners, after
being informed of the audit, persisted in their attempt to
conceal income by submitting to the IRS altered documents and
documents relating to expenses for which petitioners previously
had been reimbursed. See Rowlee v. Commissioner, 80 T.C. 1111,
1123 (1983) (stating that a taxpayer's attempts to conceal
income, mislead the IRS, or prevent the collection of income tax
may establish the requisite fraudulent intent).
Petitioners made numerous other contentions (i.e., right to
a refund, relief from joint and several liability, res judicata,
collateral estoppel, and several violations of the United States
Constitution). We conclude that these contentions are meritless
or irrelevant.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011