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filing false documents. Spies v. United States, supra at 499-
500; Douge v. Commissioner, 899 F.2d 164, 168 (2d Cir. 1990);
Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th Cir. 1986),
affg. T.C. Memo. 1984-601; Recklitis v. Commissioner, supra at
910. In examining these factors, this and other courts have
further noted that the taxpayer’s background, his or her level of
education and prior history of filing proper returns, and the
context of the events in question are relevant to the inquiry.
Plunkett v. Commissioner, 465 F.2d 299, 303 (7th Cir. 1972),
affg. T.C. Memo. 1970-274; Sowards v. Commissioner, T.C. Memo.
2003-180; Temple v. Commissioner, T.C. Memo. 2000-337, affd. 62
Fed. Appx. 605 (6th Cir. 2003).
Applying these considerations here, the Court concludes that
Mr. Richardson fraudulently intended to underpay tax for each of
the years in issue. Because matters of background and context
speak especially loudly in these unique circumstances, several
features are worthy of emphasis at the outset. As regards
personal background, Mr. Richardson was not unsophisticated. He
had passed accounting courses, possessed a business degree in
marketing, and had years of experience in business in general and
the sale of financial products in particular. Respondent’s
concession that petitioners filed correct returns prior to 1996
also speaks to an awareness of tax obligations.
With respect to context for the events in question, perhaps
the most salient feature that must inform any analysis of the
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