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would expose his criminal activity to other law enforcement
agencies. We do not find petitioner’s testimony in this regard
to be truthful. Indeed, petitioner’s plea of guilty to tax
evasion for 1989 and his admissions in his plea agreement belie
his argument.
Petitioner’s plea agreement in part states:
(2) he made an affirmative attempt to evade that tax by
failing to file an income tax return and pay the taxes
owing for that year and by engaging in the following
affirmative acts alleged in the information, namely –-
dealing extensively in cash and money orders, using
nominees to make certain expenditures, and structuring
a currency transaction in excess of $10,000 to avoid
the filing of a currency transaction report; and
(3) he acted willfully and with the intent to defraud
the government of the additional unreported taxes.
Unger also acknowledges that he engaged in similar
relevant criminal conduct with respect to his 1987 and
1990 income taxes. [Emphasis added.]
Petitioner’s admission that he engaged in similar criminal
conduct with respect to the 1987 and 1990 tax years, along with
the other evidence, is sufficiently clear and convincing that
petitioner’s understatements of tax for 1987 and 1990 were due to
fraud and that his failure to file returns for those years was
fraudulent.
The same pattern of fraud existed both before and after the
1988 tax year. Petitioner admitted to illegal narcotics
trafficking, conducted his business almost exclusively in cash,
used aliases, kept and produced no records of his transactions,
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