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Petitioner’s explanations of her behavior were implausible
and/or inconsistent. She testified that she lacked any financial
or tax expertise whatsoever. We find that she has possessed both
types of expertise since at least 1991. Two of her attorneys
even testified to that effect. Beaudry testified that petitioner
was very competent in financial matters and was intimately
involved in the bankruptcy scheme and her plan to evade taxes.
Jonathan A. Brod, another of her attorneys whom she called to
testify, described petitioner as someone who thought she was
financially astute and knowledgeable in tax matters. He
testified that she asked him an average of 60 questions a week
during the time that he represented her.
This factor weighs against petitioner.
5. Concealing Assets
Concealing assets is indicative of fraud. Id.
Petitioner purposely undertook efforts to conceal her
assets, and she purposely established the elaborate bankruptcy
scheme to conceal her ultimate receipt of the income from the
dermatology practice. In fact, the bankruptcy scheme continued
to evolve over the years in both complexity and sophistication as
petitioner asked her attorneys to hide more of her income. What
was originally conceived as an attempt to defraud her creditors
in bankruptcy evolved into a series of international transactions
whereby petitioner attempted to avoid paying Federal taxes
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