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which he did not report as income. Petitioner reported income
only to the extent that deposits were made into his personal
checking accounts and which he did not classify as “loans”.
However, the income that petitioner reported was substantially
offset by deductions that petitioner claimed for each
disbursement that he made from his personal bank accounts.87 The
items of income that respondent determined, and which he proved
by clear and convincing evidence, greatly exceed the amounts
which petitioner reported as gross income on his returns for 1985
through 1988. We find that the understatements for the years at
issue were substantial and are evidence of fraud.
Petitioner has previously understated his income in
considerable amounts and with respect to items of income
substantially similar to those items involved herein.88 On April
17, 1988, we entered a stipulated decision for deficiencies of
$1,082 for 1977, $22,213 for 1978, $63,533 for 1979, $7,110 for
1981, and $37,921 for 1982. Petitioner also understated his
income for the 1983 and 1984 tax years, and he eventually agreed
to deficiencies of $10,550 for those years. We find the
87Petitioner reported gross income from his real estate
business of $160,363 for 1985, $119,772 for 1986, $138,653 for
1987, and $61,921 for 1988. He claimed deductions for expenses
of $152,481 for 1985, $115,634 for 1986, $94,434 for 1987, and
$43,713 for 1988.
88Evidence of tax evasion for tax years which occur before
and after the filing of the return for the particular tax year at
issue is relevant on the issue of willfulness for that return.
United States v. Dixon, 698 F.2d 445, 447 (11th Cir. 1983).
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