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to fraud. Sec. 7454(a); Rule 142(b). To meet this burden,
respondent must show that petitioners intended to evade taxes
known to be owing by conduct intended to conceal, mislead, or
otherwise prevent the collection of taxes. Stoltzfus v. United
States, 398 F.2d 1002, 1004 (3d Cir. 1968); Webb v. Commissioner,
394 F.2d 366, 378 (5th Cir. 1968), affg. T.C. Memo. 1966-81;
Rowlee v. Commissioner, 80 T.C. 1111, 1123 (1983). Respondent
need not prove the precise amount of the underpayment resulting
from fraud--only that some part of the underpayment of tax for
each year at issue is attributable to fraud. Lee v. United
States, 466 F.2d 11, 16-17 (5th Cir. 1972); Plunkett v.
Commissioner, 465 F.2d 299, 303 (7th Cir. 1972), affg. T.C. Memo.
1970-274. Petitioners concede that there was unreported income
for each year at issue. We accordingly must decide whether any
part of the underpayments was due to fraud. Hebrank v.
Commissioner, 81 T.C. 640 (1983).
The existence of fraud is a question of fact to be resolved
upon consideration of the entire record. Gajewski v.
Commissioner, 67 T.C. 181, 199 (1976), affd. without published
opinion 578 F.2d 1383 (8th Cir. 1978); Estate of Pittard v.
Commissioner, 69 T.C. 391 (1977). Fraud is not to be imputed or
presumed, but rather must be established by some independent
evidence of fraudulent intent. Beaver v. Commissioner, 55 T.C.
85, 92 (1970); Otsuki v. Commissioner, 53 T.C. 96 (1969). Fraud
may not be found under "circumstances which at the most create
only suspicion." Davis v. Commissioner, 184 F.2d 86, 87 (10th
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