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or fictitious names to conceal income is also evidence of
fraud.”); see also Cooperstein v. Commissioner, T.C. Memo. 1984-
290; Yu v. Commissioner, T.C. Memo. 1973-188; Staff v.
Commissioner, T.C. Memo. 1954-59.
As we have noted throughout this opinion, petitioner has
consistently failed to maintain adequate records of his real
estate and other transactions. In some cases, the only record
petitioner admits to have maintained is his checkbook. Clearly,
a checkbook is an insufficient record for purposes of computing
his gross income, especially where the transactions involved are
complex real estate transactions which include installment sales
and subdividing. Such a gross failure to maintain adequate
records (or to provide such records) is certainly indicative of
fraud. See Clayton v. Commissioner, 102 T.C. at 647.
We hold that there is clear and convincing evidence of
fraudulent intent to evade income taxes by petitioner and that
the circumstances which lead us to that holding were apparent
with respect to at least some part of the underpayments for each
of the tax years in issue. Thus, with respect to the 1985 tax
year, respondent has satisfied his burden, and the addition to
tax under section 6653(b)(1) applies to the entire underpayment;
with respect to the 1986, 1987, and 1988, tax years respondent
has satisfied his initial burden, and the additions to tax for
fraud for those tax years apply to the entire underpayment unless
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