Page:T.C. Memo. 2012-281.pdf/54

[*54] contrast, respondent introduced credible evidence that petitioner provided no records to Special Agent Schneider and that petitioner misled Special Agent Schneider about the amounts of, and her access to, cash hoards at the 29 Cummings Road property. Respondent also introduced credible evidence that petitioner and her attorney attempted to impede Revenue Agent AlyceFaye's civil investigation of petitioner. Petitioner attempted to cooperate with respondent only after she had already exerted considerable resistance to respondent's collection efforts. , 252 F.2d 56, 61 (9th Cir. 1958). Petitioner's failure to cooperate with tax authorities is indicative of fraud.

Engaging in illegal activity, even if the taxpayer is not charged with a tax crime, is circumstantial evidence of fraud. , 99 ___________