- 33 - 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.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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