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See Recklitis v. Commissioner, 91 T.C. 874, 910 (1988). Those
badges include a pattern of understatement of income, failure to
file tax returns, implausible or inconsistent explanations of
behavior, concealing assets, and failure to cooperate with tax
authorities. See, e.g., Bradford v. Commissioner, 796 F.2d 303,
307-308 (9th Cir. 1986), affg. T.C. Memo. 1984-601. Each of
those badges is present in this case. Petitioner’s use of false
Federal identification numbers to conceal bank accounts and
failure to make estimated tax payments are further evidence of
his intent to conceal income and prevent the collection of tax.
See Rowlee v. Commissioner, 80 T.C. 1111, 1123 (1983); Leggett v.
Commissioner, T.C. Memo. 1999-100, affd. 221 F.3d 1357 (11th Cir.
2000). We conclude that respondent has proven fraud for each
year by clear and convincing evidence.
It is well settled that a conviction under section 7201
collaterally estops a taxpayer from denying fraud for purposes of
former section 6653(b). See Blohm v. Commissioner, 994 F.2d
1542, 1554 (11th Cir. 1993), affg. T.C. Memo. 1991-636; Amos v.
Commissioner, 43 T.C. 50, 54-56 (1964), affd. 360 F.2d 358 (4th
Cir. 1965). In view of the substantive identity between the
elements considered under section 6653(b)(1) and section 6651(f),
petitioner’s conviction under section 7201 for the years 1990
through 1993 collaterally estops him from denying fraud for those
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