- 36 -                                                  
            in the amounts of $305,270, $50,000, $278,982, and $100,000.  We                           
            think it is unlikely that petitioner “accidentally” routed only                            
            his largest fees around his Business Account.  The sheer size of                           
            the omissions for all years supports a finding that the omissions                          
            were intentional rather than accidental.  The fact that                                    
            petitioner deposited these checks into personal accounts or                                
            endorsed them over to family members made it difficult for                                 
            respondent to trace the proceeds to petitioner and is indicative                           
            of an intent to evade taxes.  Petitioner’s attempt to blame his                            
            office staff and former return preparer for these omissions of                             
            income is weak and implausible.                                                            
                  Furthermore, petitioner failed to provide any explanation                            
            for the underreporting of interest income and capital gains.                               
            With regard to petitioner’s capital gains adjustment relating to                           
            the Sipsey Harbor transactions, the evidence supports the finding                          
            that six lots of Sipsey Harbor were sold in 1989 and 1990.                                 
            Petitioner argued that he disposed of Sipsey Harbor in a single                            
            transaction and that he was reporting the sale under the                                   
            installment method.  Petitioner, however, did not report the                               
            Sipsey Harbor transaction on any tax return.  Regardless of which                          
            accounting method petitioner chose to utilize regarding the                                
            transaction, petitioner offered no explanation for his complete                            
            failure to report any Sipsey Harbor transaction.  Petitioner also                          
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