Page:T.C. Memo. 2012-281.pdf/46

[*46] engaging in extensive dealings in cash. , 796 F.2d at 307-308;, 94 T.C. 654, 664-65 (1990); , 91 T.C. 874, 910 (1988); , 21 T.C. 917 (1954), , 220 F.2d 871 (4th Cir. 1955); , T.C. Memo. 2003-332,, 419 F.3d 829 (8th Cir. 2005). The existence of any one factor is not dispositive, but the existence of several factors is persuasive circumstantial evidence of fraud. , 99 T.C. 202, 211 (1992);, 92 T.C. at 700.

Respondent contends that the following factors are present in this case: (1) petitioner understated her income for the years at issue; (2) petitioner failed to maintain adequate records for the years at issue; (3) petitioner offered implausible or inconsistent explanations with regard to her role at CSE and her recordkeeping during the years at issue; (4) petitioner concealed income and assets for the years at issue; (5) petitioner failed to cooperate with tax authorities regarding the years at issue; (6) petitioner engaged in, and concealed, illegal activities during the years ___________