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account. There is also no evidence that the funds deposited in
(or sent to) the Bahamian bank were derived from (or were
intended for use in) any illegal activity. Furthermore, we are
aware that the ownership or use by a U.S. person of a foreign
bank account, including a Bahamian bank account, is not illegal.
We note, however, that the checks deposited in (or sent to)
the Bahamian bank were White Co. checks, payable to petitioner's
plumbing business. Several of the checks respondent used to
reconstruct petitioner's stipulated gross receipts in 1991 and
1992 were also White Co. checks, and the parties have stipulated
that for the years 1989-92, petitioner received payments for
services from White Co. totaling $183,285. Moreover, during each
of the years 1989-92, petitioner used the same incorrect Social
Security number on the invoices he submitted to, and on his
contracts with, general contractors for construction projects.
Finally, the stipulated use of the Bahamian bank account occurred
after the Commissioner's Criminal Investigation Division had
notified petitioner that it was investigating petitioner's tax
liability for 1989-92.
In light of these and all other facts in the record, we hold
that the stipulated facts concerning petitioner's use of the
Bahamian bank account are admissible, relevant, probative
evidence of petitioner's intent (in failing to file tax returns
for 1989-92) to conceal income or assets (including moneys
received from White Co.) earned or owned during 1989-92, and
thereby evade the payment of taxes believed to be owed for those
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