Albert M. Graham and Martha A. Graham - Page 45

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          having Sieveke and John Gueren collect attorney’s fees owed to              
          petitioner and delivering them to O’Leary, who deposited those              
          funds in his money market account and then funneled the funds to            
          Edgar and back to petitioner.  Petitioner told Edgar he was doing           
          this because he thought he was paying too much tax.                         
                    g.   Giving Implausible or Inconsistent Explanations              
               Implausible or inconsistent explanations of behavior by a              
          taxpayer can show fraudulent intent.  Korecky v. Commissioner,              
          781 F.2d 1566, 1568 (11th Cir. 1986), affg. T.C. Memo. 1985-63;             
          Bradford v. Commissioner, supra at 307; Bahoric v. Commissioner,            
          363 F.2d 151, 153 (9th Cir. 1966), affg. T.C. Memo. 1963-333.               
          Many of petitioner’s explanations of his behavior were                      
          implausible or inconsistent.                                                
               Petitioner testified inconsistently regarding the                      
          distributions from the Anis partnership.  He testified that his             
          children received a $47,000 distribution in 1995, which they lent           
          to him, but he thought the money was theirs because they were               
          members of the Anis partnership.  He also testified that any cash           
          that came out of the Anis partnership in 1995 belonged to him,              
          that he didn’t know whether the money was received by himself or            
          his children, and that he chose not to be a partner in the                  
          partnership only with respect to the parcels of real property               
          held by the partnership.                                                    
               Petitioner’s testimony concerning Edgar’s computer records             
          was vague and contradictory.  He testified that he did not print            




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