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authorities; (3) inadequate books and records; (4) concealing
assets; (5) filing false documents; and (6) implausible or
inconsistent explanations of behavior. Spies v. United States,
supra at 499; Bradford v. Commissioner, 796 F.2d 303, 307-308
(9th Cir. 1986), affg. T.C. Memo. 1984-601; DiLeo v.
Commissioner, supra at 875. While no single indicium is
necessary or sufficient to find fraud, the existence of several
of these factors is persuasive circumstantial evidence of
fraudulent intent. Petzoldt v. Commissioner, supra at 700.
Petitioner consistently understated his income by
substantial amounts for the years 1990, 1991, and 1992.
Petitioner failed to cooperate with tax authorities.
Petitioner’s effort to prevent respondent from obtaining
information from the H&R Block employee shows that he attempted
to impede respondent’s investigation and indicates that
petitioner intended to evade taxes. See Truesdell v.
Commissioner, 89 T.C. 1280, 1303 (1987) (finding that the
taxpayer’s “interference with * * * [the Commissioner’s]
investigation is also indicative of his intent to conceal the
diverted income and evade tax”). Also, as discussed supra,
petitioner did not submit any books or records to respondent’s
agent during the course of the examination of his 1990, 1991, and
1992 income tax returns.
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