- 64 - fraud.” Truesdell v. Commissioner, 89 T.C. 1280, 1302 (1987); Marcus v. Commissioner, 70 T.C. 562, 577 (1978), affd. without published opinion 621 F.2d 439 (5th Cir. 1980). For 1994, Michael reported $68,758 of Schedule C gross receipts from the plumbing business. Respondent has shown by clear and convincing evidence that Michael should have reported at least $85,683. Supra table 7. We conclude that the $16,925 difference is a substantial underreporting. For 1995, Michael reported $82,721 of Schedule C gross receipts from the plumbing business. Respondent has shown by clear and convincing evidence that Michael should have reported at least $162,038. Supra table 8. We conclude that the $79,317 difference is a substantial underreporting. For the 2 years in issue, Michael failed to report an aggregate of about 40 percent of his Schedule C gross receipts from the plumbing business. (2) Failure To Keep Adequate Books and Records Taxpayers are required to maintain books and records sufficient to show their tax liabilities. See sec. 6001. Failure to do so is another indicium of fraudulent intent. See Bradford v. Commissioner, 796 F.2d at 307. Respondent contends that petitioners’ records for the plumbing business were incomplete and inconsistent. For 1995, respondent points to the fact that the total amount of the addingPage: Previous 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 Next
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