-26-
Finally, petitioner has not asserted he was acting under a
good-faith belief that his nonfiling for the years in issue was
permitted by law. Cf. Cheek v. United States, 498 U.S. 192
(1991). The existence of any such belief is belied by the
admissions in his 1980 letter.
The foregoing evidence clearly and convincingly proves that
petitioner's failure to file a return for each of the years 1989-
92 constituted a willful, intentional violation of a known legal
duty. In addition, under the circumstances of this case,
petitioner's repeated and prolonged failure to file returns is
strong and persuasive evidence that petitioner, by not filing
returns for 1989-92, intended fraudulently to evade taxes owed
for those years, by concealing his income and assets from the
Commissioner. See Stoltzfus v. United States, supra; Powell v.
Granquist, supra.
2. Other Evidence of Fraud
There is substantial evidence, in addition to petitioner's
history of nonfiling, that the underpayments in petitioner's
taxes for 1989-92 were due to fraud.
First, petitioner was responsible for the recordkeeping of
his plumbing business. In each of the years in issue, petitioner
did not maintain, as books and records, invoices, receipts for
cash disbursements, a general ledger, a cash receipts journal, or
a cash disbursements journal. Taxpayers are required to maintain
adequate records. See sec. 6001. Under the circumstances of
this case, we find that petitioner's maintenance of inadequate
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