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additional deductions, respondent offered clear and convincing
evidence that there were underpayments for each year in issue.
See House v. Commissioner, T.C. Memo. 2000-22.
The record is replete with evidence of petitioner’s
fraudulent intent. Over a 3-year period, petitioner consistently
underreported large amounts of gross receipts and net income. A
consistent pattern of underreporting large amounts of income is
evidence of fraud. See Holland v. United States, 348 U.S. 121,
137 (1954); Merritt v. Commissioner, 301 F.2d 484 (5th Cir.
1962), affg. T.C. Memo. 1959-172.
Petitioner is a tax professional and a C.P.A. who prepares
tax returns for a living and represents clients before the
Internal Revenue Service. His experience and knowledge of the
tax laws is circumstantial evidence that he was aware of his
obligation to report his income and that in consistently
underreporting his income, he did so with fraudulent intent. See
Solomon v. Commissioner, 732 F.2d 1459, 1461-1462 (6th Cir.
1984), affg. T.C. Memo. 1982-603; Beaver v. Commissioner, 55 T.C.
85, 93 (1970). As previously discussed, his explanations of his
unreported income were implausible and unconvincing. We view
petitioner’s lack of credibility as circumstantial evidence of
his fraudulent intent.
Petitioner boasted to the undercover CID agents that he
disguised personal expenses incurred on personal trips in his
aircraft as business expenses. The use of a business to cloak
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