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basis of the entire record. Gajewski v. Commissioner, 67 T.C.
181, 199 (1976), affd. without published opinion 578 F.2d 1383
(8th Cir. 1978). Fraud, however, can seldom be proved by direct
proof of the taxpayer's intention. Fraud can be established by
circumstantial evidence and by reasonable inferences drawn from
the taxpayer's entire course of conduct. Spies v. United States,
317 U.S. 492, 499 (1943); Toussaint v. Commissioner, 743 F.2d at
312; Gajewski v. Commissioner, supra at 200.
Courts frequently list various factors or "badges of fraud"
from which fraudulent intent may be inferred. Recklitis v.
Commissioner, 91 T.C. 874, 909 (1988). Although such lists are
nonexclusive, some of the factors this Court has considered as
indicative of fraud are (1) understatement of income, (2)
inadequate records, (3) implausible or inconsistent explanations
of behavior, (4) concealment of assets, and (5) failure to
cooperate with the tax authorities. Niedringhaus v.
Commissioner, 99 T.C. 202, 211 (1992) (citing Bradford v.
Commissioner, 796 F.2d 303, 307-308 (9th Cir. 1986), affg. T.C.
Memo. 1984-601). These indicia are amply present here, as set
forth in the findings of fact.
The taxpayer's evasiveness on the stand, inconsistencies in
his testimony, and the lack of credibility of such testimony are
heavily weighted factors in considering the fraud issue.
Toussaint v. Commissioner, supra at 312. Petitioner was not
credible. His testimony was highly inconsistent concerning his
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