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evidence, id. at 875, which includes the various indicia or
badges of fraud relied upon by the courts, see Bradford v.
Commissioner, 796 F.2d 303, 307 (9th Cir. 1986), affg. T.C. Memo.
1984-601; DiLeo v. Commissioner, supra at 875. A combination of
several badges of fraud constitutes persuasive circumstantial
evidence of fraud. Niedringhaus v. Commissioner, 99 T.C. 202,
211 (1992); Petzoldt v. Commissioner, 92 T.C. 661, 700 (1989).
Respondent has established that petitioner underpaid his
income tax for each of the years at issue. The bank deposits
analysis reflects substantial deposits into petitioner’s bank
accounts for each year. The record contains substantial credible
evidence that the deposits were income to petitioner. When this
fact is coupled with the uncontested fact that petitioner was
required to file but failed to file tax returns for the years at
issue, we find that the record contains clear and convincing
proof that petitioner underpaid his income tax for each of the
years at issue.
Respondent’s proof that petitioner’s underpayments are
attributable to fraud consists primarily of petitioner’s deemed
admissions. We have held that deemed admissions are sufficient
to satisfy the Commissioner’s burden of proof with respect to the
issue of fraud. See Doncaster v. Commissioner, 77 T.C. 334, 336-
338 (1981).
According to respondent, petitioner’s deemed admissions
establish the following indicia or badges of fraud for all years
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