Andrew Toussaint and Isela C. Toussaint v. Commissioner of Internal Revenue

ROBERT M. HILL, Circuit Judge:

The United States Tax Court, Whitaker, J., assessed against Andrew Toussaint in come tax deficiencies and penalties for fraudulent underpayment of income taxes for the taxable years 1971-1975. 1 Toussaint appeals, arguing that the tax court’s decision was not supported by sufficient evidence. Because we find no clear error in the tax court’s decision, we affirm.

Toussaint, a resident of Houston, Texas, is a former Internal Revenue Service (I.R.S.) agent who now operates a used car lot. He claims that on July 9, 1974, a painting which he had possessed for several…