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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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