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(4) implausible or inconsistent explanations of behavior;
(5) concealment of income or assets; (6) failure to cooperate
with tax authorities; (7) engaging in illegal activities;
(8) dealing in cash; (9) failure to make estimated tax payments;
and (10) filing false documents. Spies v. United States, supra
at 499-500; Douge v. Commissioner, 899 F.2d 164, 168 (2d Cir.
1990); Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th Cir.
1986), affg. T.C. Memo. 1984-601; Recklitis v. Commissioner,
supra at 910. In addition, a conviction pursuant to section
7206(1), while not operating collaterally to estop a taxpayer
from denying fraudulent intent, is a fact to be considered and
may give rise to an inference of intent to evade. Wright v.
Commissioner, supra at 643-644; see also Biaggi v. Commissioner,
T.C. Memo. 2000-48, affd. 8 Fed. Appx. 66 (2d Cir. 2001); Wilson
v. Commissioner, T.C. Memo. 1994-454; Avery v. Commissioner, T.C.
Memo. 1993-344.
Applying these considerations to this case, we conclude that
petitioner fraudulently intended to underpay tax for each of the
years in issue. The record demonstrates that petitioner
understated his income, maintained inadequate records, engaged in
illegal activities, and dealt in cash. Moreover, the convictions
under section 7206(1) are highly probative. The logical
inference to be drawn from such circumstances is that petitioner
structured his affairs with a purpose of avoiding his Federal tax
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