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Respondent’s burden with respect to fraudulent intent is met
if it is shown that the taxpayer intended to conceal, mislead, or
otherwise prevent the collection of taxes owing. See, e.g., Webb
v. Commissioner, 394 F.2d 366, 377 (5th Cir. 1968), affg. T.C.
Memo. 1966-81. Fraud may be proved by circumstantial evidence
because direct proof of the taxpayer’s intent is rarely
available. The taxpayer’s entire course of conduct may establish
the requisite fraudulent intent. Stone v. Commissioner, 56 T.C.
213, 223-224 (1971); Otsuki v. Commissioner, 53 T.C. 96, 105-106
(1969). Fraudulent intent may be inferred from various “badges
of fraud”, including understatement of income, implausible or
inconsistent explanations of behavior, concealing assets, and
failure to cooperate with tax authorities. See Bradford v.
Commissioner, 796 F.2d 303, 307 (9th Cir. 1986); Webb v.
Commissioner, supra at 379; Marcus v. Commissioner, 70 T.C. 562,
577 (1978), affd. without published opinion 621 F.2d 439 (5th
Cir. 1980). A taxpayer’s education may be considered in
determining whether or not he had fraudulent intent. See, e.g.,
Scallen v. Commissioner, 877 F.2d 1364, 1370-1371 (8th Cir.
1989), affg. T.C. Memo. 1987-412.
In this case, respondent has presented clear and convincing
evidence that petitioner had taxable income for each of the years
in issue and that he failed to report substantial amounts of that
income on his returns. There is evidence, and we have found,
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