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taxpayer’s correct liability, implausible or inconsistent
explanations of behavior, concealment of assets, and failure to
make estimated tax payments. See, e.g., Bradford v.
Commissioner, 796 F.2d 303, 307-308 (9th Cir. 1986), affg. T.C.
Memo. 1984-601; Powell v. Granquist, 252 F.2d 56, 60 (9th Cir.
1958); Grosshandler v. Commissioner, 75 T.C. 1, 20 (1980);
Gajewski v. Commissioner, 67 T.C. 181, 199 (1976), affd. without
published opinion 578 F.2d 1383 (8th Cir. 1978).
Petitioner stipulated to the payments received from 1988
through 1997. He admitted during his testimony that he received
funds for work performed during each of the years in issue.
Proof of gross receipts is sufficient to satisfy respondent’s
burden of showing an underpayment for 1987 and 1988 in the
absence of evidence of offsetting deductions. See, e.g.,
Greenwood v. Commissioner, T.C. Memo. 1990-362. Petitioner has
neither argued nor shown that he had any offsetting deductions
not allowed in respondent’s determination.
In defending the charge of fraud, petitioner attempts to
rely on his letters openly stating his position to the IRS.
Those letters, however, commenced only after his failure to
comply with his obligations had been discovered. They are not
persuasive evidence negating fraud. See Rowlee v. Commissioner,
supra at 1124.
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