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          underpayment of tax for each of the years in issue.  Over the 4-            
          year period in issue, petitioners failed to report approximately            
          $1 million dollars of income.                                               
                    2.   False Statements                                             
               Respondent argues that false statements made at the time               
          petitioners were interviewed by respondent’s agents are evidence            
          of fraudulent intent.  The Supreme Court has stated that an                 
          "affirmative willful attempt may be inferred from * * * any                 
          conduct, the likely effect of which would be to mislead or to               
          conceal."  Spies v. United States, supra at 499.  Making false              
          statements to a revenue agent is evidence of fraud.  See United             
          States v. Beacon Brass Co., 344 U.S. 43, 45 (1952).                         
               When petitioners first met with respondent’s special agents            
          regarding the years in question, Mr. Bacon told them that                   
          petitioners and their children had received extensive cash gifts            
          from Mr. Bacon’s grandfather in $10,000 cash increments.                    
          According to Mr. Bacon, he received a $10,000 cash gift each year           
          since his 18th birthday, his wife received an annual $10,000 cash           
          gift since they have been married, and their children each                  
          received an annual $10,000 cash gift since their birth.  Mr.                
          Bacon told respondent’s agents that he received the cash gifts              
          through a brother-in-law, that neither petitioners nor their                
          children had ever met their grandfather, that they were told                
          never to tell anyone about the gifts, and that they were never to           
          put the money in the bank.  Mr. Bacon told the agents that                  
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