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a copy. We admitted this document in part based upon
petitioner’s assurance to the Court that she had the original.
Several days later, petitioner admitted that she had no idea
where the original of this document was. One of petitioner’s
employees testified that the pegboard register was not for the
client trust account ledger as petitioner alleged it to be and
that petitioner may have fabricated the pegboard register.
Another of petitioner’s employees did not recall seeing this
register. We conclude that the pegboard register admitted at
trial was fabricated by petitioner, and that petitioner’s
creation and submission of this document is further evidence of
fraud.
Last, although not dispositive, petitioner’s conviction
under section 7206(1) is probative evidence that she intended to
evade her taxes. See Wright v. Commissioner, 84 T.C. 636, 643-
644 (1985).
C. Petitioner’s Arguments
1. Mr. Reiter’s Credibility
Petitioner attacks the credibility of Mr. Reiter and
suggests we should not rely on his testimony. Mr. Reiter may
have engaged in some inappropriate conduct; however, in all
important respects, Mr. Reiter’s testimony was corroborated or
supported by two members of his staff, four employees of the law
firm, and/or respondent’s employees who testified at trial.
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