- 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 alsoPage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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