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We found Katherine’s and her siblings’ testimony conflicting
and implausible for the most part. We agree with respondent that
Katherine’s highly implausible and incredible story of receiving
a substantial cash hoard from her father is another indication of
fraudulent intent.
(8) Level of Education, Age, and State of Health
Petitioners contend that Frank and Katherine had no formal
education and were illiterate. Additionally, petitioners contend
that during the years in issue Frank and Katherine were elderly,
unsophisticated, and suffering from serious illnesses.
Petitioners assert that Frank and Katherine relied on their
accountant to prepare their returns because of their lack of
education. Petitioners, in effect, argue that those factors
negate any inferences of fraud on the part of Frank or Katherine.
Under the circumstances here presented, we do not agree with
petitioners’ position that Frank’s and Katherine’s lack of formal
education, illiteracy, age, lack of sophistication, or health
negate inferences of fraud. Although Frank and Katherine may
have had no formal education, they do not appear from the record
to have lacked business acumen or sophistication. Dr. Schwartz
described Katherine as a bright woman and sharp most of the time.
Katherine ran a successful palmistry business for more than
50 years. The circumstance that Katherine kept some records
relating to her business that she gave to Baptiste for the
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