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There is no credible evidence that the deposits were from
nontaxable sources. We simply do not believe that the money came
from gifts or loans from petitioner's father. Petitioner failed
to call any family members (his mother, sister, or brother-in-
law) in an effort to verify his stories. We thus infer that
their testimony would have been unfavorable. Wichita Terminal
Elevator Co. v. Commissioner, 6 T.C. 1158 (1946), affd. 162 F.2d
513 (10th Cir. 1947).
Petitioner did not produce any evidence of so-called flow-
throughs. Neither did he explain away the payment of his
personal expenses (sometimes disguised in corporate names) out of
the MIT account. Respondent has met her burden of showing the
understatements of income for both years in issue.
Fraud is actual, intentional wrongdoing, and the intent is
the specific purpose to evade a tax believed to be owing.
Stoltzfus v. United States, 398 F.2d 1002, 1004 (3d Cir. 1968);
Webb v. Commissioner, 394 F.2d 366, 377 (5th Cir. 1968), affg.
T.C. Memo. 1966-81. Respondent must show that petitioner
intended to evade taxes by conduct calculated to conceal,
mislead, or otherwise prevent the collection of the tax.
Stoltzfus v. United States, supra at 1004; Webb v. Commissioner,
supra at 377.
Fraud is never to be presumed. Toussaint v. Commissioner,
supra at 312; Webb v. Commissioner, 394 F.2d at 377. The
existence of fraud is a question of fact to be determined on the
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