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T.C. 874, 910 (1988). Although no single factor is necessarily
sufficient to establish fraud, the combination of a number of
factors constitutes persuasive evidence. Solomon v.
Commissioner, 732 F.2d 1459, 1461 (6th Cir. 1984), affg. per
curiam T.C. Memo. 1982-603.
The evidence establishing petitioner’s fraudulent intent is
overwhelming. First, petitioner was an attorney, and she took
one course in taxation during law school.
Second, petitioner consistently and substantially
understated her income. This is strong evidence of fraud when
coupled with other circumstances. Marcus v. Commissioner, 70
T.C. 562, 577 (1978), affd. without published opinion 621 F.2d
439 (5th Cir. 1980). A pattern of consistent underreporting of
income, when accompanied by other circumstances indicating an
intent to conceal income, may justify the inference of fraud.
Holland v. United States, 348 U.S. 121, 139 (1954).
Third, petitioner’s explanations were implausible and
inconsistent. She kept changing her story to fit the
circumstances she was faced with. As the agents, and the Court,
learned the truth, petitioner would change her story.
Fourth, petitioner attempted to conceal her true income by
depositing it into her Merrill Lynch account.
Fifth, petitioner failed to cooperate with tax authorities.
She attempted to prevent Merrill Lynch from complying with a
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