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Mr. G is a practicing accountant. He prepared tax returns for many clients. His practice was to secure from clients a check payable to him covering the amount of the tax due plus his fee. This amount he deposited in a special trust account he drew checks payable to the IRS. He failed to make all the payments required to pay his clients' taxes. Some shortages in his trust account were traceable to his practice of accommodating some of his clients with loans or advances. He also drew on the trust account for loans or advances for personal use. He fell behind in filing returns and remitting payments. He filed for numerous six-month extensions for his clients. Is Mr. G guilty of an attempt to evade or defeat tax? Why or Why not?

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