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extensive dealings in cash. Bradford v. Commissioner, 796 F.2d
at 307; Parks v. Commissioner, 94 T.C. 654, 664 (1990); Temple v.
Commissioner, T.C. Memo. 2000-337. No single factor is
necessarily dispositive, but a combination of several factors is
persuasive circumstantial evidence of fraud. Petzoldt v.
Commissioner, 92 T.C. at 699. “A pattern of consistent
underreporting of income, particularly when accompanied by other
circumstances exhibiting an intent to conceal, justifies the
inference of fraud.” Posnanski v. Commissioner, supra; see
Holland v. Commissioner, 348 U.S. 121, 137 (1954).
Petitioner consistently underreported large sums of money.
See Marcus v. Commissioner, 70 T.C. 562, 577 (1978), affd.
without published opinion 621 F.2d 439 (5th Cir. 1980).
Petitioner’s failure to substantiate adequately his alleged
advances and expenses makes it impossible to verify his
allegations. This Court has found in a similar case that the
“inadequacy of petitioners’ records, under the circumstances,
constitutes a significant indicia of fraud.” Otsuki v.
Commissioner, 53 T.C. at 110 (citing Galant v. Commissioner, 26
T.C. 354, 365 (1956)).
Petitioner cannot rely upon events that occurred in his life
before, during, and after the relevant periods in issue. While
we are sympathetic with petitioner’s personal problems, we cannot
condone his failure to report significant sums of income over a
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