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concealing assets; (5) engaging in illegal activities; and (6)
dealing in cash. See Bradford v. Commissioner, 796 F.2d 303,
307-308 (9th Cir. 1986), affg. T.C. Memo. 1984-601; Recklitis v.
Commissioner, 91 T.C. 874, 910 (1988); Rowlee v. Commissioner,
supra at 1125. A showing of the taxpayer’s willingness to
defraud others is also relevant in determining whether he
committed fraud with respect to his income tax obligations. See
McGee v. Commissioner, 61 T.C. 249, 260 (1973), affd. 519 F.2d
1121 (5th Cir. 1975). Moreover, engaging in conduct to avoid
currency-reporting provisions also evidences the type of
concealment indicative of tax fraud. See Parks v. Commissioner,
94 T.C. 654, 665 (1990); Podolece v. Commissioner, T.C. Memo.
1992-227; Savage v. Commissioner, T.C. Memo. 1992-129; Sea Sports
Center, Inc. v. Commissioner, T.C. Memo. 1991-209, affd. without
published opinion 979 F.2d 1537 (11th Cir. 1992); Morris v.
Commissioner, T.C. Memo. 1990-580.
On the basis of our review of the entire record, we believe
respondent has shown by clear and convincing, indeed
overwhelming, evidence that both petitioners committed fraud for
each of the years in issue. An examination of the dual sets of
records maintained by petitioners, together with the
circumstances under which such records came to light and Mr.
Karcho’s recurrent dealings in large amounts of cash (which led
to a structuring conviction), leads inescapably to the conclusion
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