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income and to pay taxes thereon. Her excuses include the
improbable contention that her now-deceased attorney informed her
that she was not required to file personal or corporate tax
returns, her tales of theft of records, and her steadfast denials
that she earned any income from an escort business. She also
altered a document in a material respect that she sought to
introduce as evidence in this case. These dubious claims and
actions are the kinds of implausible or deceitful representations
that serve as circumstantial evidence of fraud. Finally,
petitioner’s actions in these proceedings reveal that she is
intelligent, shrewd, and experienced in financial matters. Her
efforts to interpose a sham corporate entity between herself and
her tax obligations confirm this view. We conclude that she was
aware of her obligation to file tax returns and pay tax for 1989
and 1990, and that her failure to do so was a willful attempt to
evade those responsibilities, which is fraudulent within the
meaning of section 6651(f).23
For the taxable years 1991 and 1992, however, it has not
been established that petitioner had sufficient gross income to
require the filing of income tax returns. It follows that she is
not liable for any addition to tax under section 6651 for those
years.
23 Because we conclude that petitioner’s failure to file in
1989 and 1990 was fraudulent, we need not address respondent’s
alternative determinations under sec. 6651(a).
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