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Sloan, 939 F.2d 499 (7th Cir. 1991); United States v. Collins,
920 F.2d 619 (10th Cir. 1990); United States v. Ward, supra;
United States v. Schiff, 801 F.2d 108 (2d Cir. 1986); United
States v. Karlin, 785 F.2d 90 (3d Cir. 1986); United States v.
Bressler, 772 F.2d 287 (7th Cir. 1985); United States v. Romero,
640 F.2d 1014 (9th Cir. 1981); United States v. Buras, 633 F.2d
1356 (9th Cir. 1980).
When, as here, accompanied by evidence of intent to conceal
income and assets, the longtime pattern of failing to file tax
returns is sufficient to sustain the civil penalties. See, e.g.,
Niedringhaus v. Commissioner, supra at 212-213; Rowlee v.
Commissioner, supra; Marsh v. Commissioner, T.C. Memo. 2000-11,
affd. 23 Fed. Appx. 874 (9th Cir. 2002); Houser v. Commissioner,
T.C. Memo. 2000-111; Harrell v. Commissioner, T.C. Memo.
1998-207, affd. without published opinion 191 F.3d 456 (7th Cir.
1999); Dunham v. Commissioner, T.C. Memo. 1998-52. The penalties
for fraud in this case will be sustained.
As indicated above, our conclusion that petitioner’s
underpayment of taxes and failure to file returns was due to
fraud is based on the objective facts and rejection of his claims
of good faith. Our reasoning is supported in part by his refusal
to acknowledge that his positions are contrary to law, as he was
advised by the IRS, relevant authorities, and the Court in this
case. Petitioner persists in his frivolous and groundless
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