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activities; (8) attempting to conceal illegal activities;
(9) dealing in cash; (10) failing to make estimated tax payments;
and (11) filing false documents. See Spies v. United States,
supra at 499; Bradford v. Commissioner, supra at 307-308.
Additional factors to be considered include the taxpayer’s
background, level of education, and prior history of filing
proper returns. Niedringhaus v. Commissioner, 99 T.C. 202, 211
(1992).
The instant case involves many “badges” of fraud.
Accordingly, the Court concludes that Mr. Wright fraudulently
intended to underpay taxes for 1999, 2000, and 2001. Notably,
Mr. Wright is sophisticated in tax matters. He is a certified
public accountant and certified financial planner, has a master’s
degree in business administration, and owns and operates an S
corporation that provides accounting services and tax advice to
its clients. Additionally, Mr. Wright failed to cooperate with
the tax authorities. Mr. Wright was not a credible witness as he
frequently gave inconsistent and implausible answers to questions
asked during trial.
Specifically in 1999, Mr. Wright concealed income by
transferring $54,000 to petitioners’ offshore bank account. Mr.
Wright structured petitioners’ $54,000 deposit transaction
specifically to avoid the exportation of monetary instruments
reporting requirements. Additionally, Mr. Wright constructed a
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