- 20 - 121, 137 (1954)); Camien v. Commissioner, 420 F.2d 283, 287 (8th Cir. 1970), affg. T.C. Memo. 1968-12. Respondent contends that the following badges of fraud exist in this case: (1) Inadequate records; (2) implausible or inconsistent explanations; (3) a pattern of behavior indicating an intent to mislead; and (4) filing false documents. On brief, petitioner presented frivolous and irrelevant arguments as to the credibility of the various witnesses, ignoring the documentation and receipts at issue. The Court agrees with respondent. The record establishes without a doubt that petitioner maintained and presented inadequate and false records with respect to the deductions claimed on his 2002 and 2003 returns. Respondent clearly and convincingly showed, through the use of credible witnesses, that a substantial number of documents attached to petitioner’s 2002 and 2003 returns in an effort to establish the propriety of his deductions for both years were forged or falsified. Moreover, the documents presented for this case are strikingly similar to those submitted to substantiate petitioner’s claimed 2001 deductions in Prowse v. Commissioner, T.C. Memo. 2006-120, and which the Court likewise found were altered. Several professionals, such as doctors, testified at trial that, while they had provided services to petitioner in prior years, they had not provided services to petitioner as purportedly claimed on the receipts that were submitted to thePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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