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796 F.2d 303, 307 (9th Cir. 1986), affg. T.C. Memo. 1984-601;
Recklitis v. Commissioner, 91 T.C. 874, 910 (1988). This list is
nonexclusive. Although no single factor is necessarily
sufficient to establish fraud, the combination of a number of
factors constitutes persuasive evidence of fraud. Solomon v.
Commissioner, 732 F.2d 1459, 1461 (6th Cir. 1984), affg. per
curiam T.C. Memo. 1982-603; Miller v. Commissioner, 94 T.C. 316,
334 (1990).
The record in this case supports our holding that petitioner
fraudulently intended to evade 1991 and 1992 income tax.
Petitioner was receiving the proceeds from Gene’s, and he
intentionally and consistently understated that income. His
testimony was evasive and to some extent not credible.
Petitioner fabricated records of income and intentionally
discarded cash register tapes, which would have shown the true
sales of Gene’s. He concealed income by fabricating his daily
sales summary sheets and admitted to respondent’s agents that he
underreported the sales income of Gene’s by approximately $15,000
per month. Petitioner dealt in cash and did not maintain records
of his cash transactions involving the purchase of inventory.
Petitioner pleaded guilty to and was convicted of criminal income
tax evasion under section 7201 for the year 1992. In that
regard, we have already held that petitioner is collaterally
estopped from denying that part of the underpayment for 1992 is
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