- 33 - 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 aPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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