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only with respect to that year. Respondent must show that
petitioner intended to evade taxes known or believed to be owing
by conduct intended to conceal, mislead, or otherwise prevent the
collection of taxes. Korecky v. Commissioner, 781 F.2d at 1568;
Stoltzfus v. United States, 398 F.2d 1002, 1004 (3d Cir. 1968);
Webb v. Commissioner, 394 F.2d at 377; Rowlee v. Commissioner, 80
T.C. 1111, 1123 (1983). 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, 106 (1969). However,
fraud need not be established by direct evidence, which is rarely
available, but may be proved by surveying the taxpayer’s entire
course of conduct and drawing reasonable inferences therefrom.
Spies v. United States, 317 U.S. 492, 499 (1943); Korecky v.
Commissioner, supra at 1568; Rowlee v. Commissioner, supra at
1123; Stephenson v. Commissioner, 79 T.C. 995, 1006 (1982), affd.
748 F.2d 331 (6th Cir. 1984). Although fraud may not be found
under "circumstances which at the most create only suspicion",
Petzoldt v. Commissioner, 92 T.C. at 700, the intent to defraud
may be inferred from any conduct the likely effect of which would
be to conceal, mislead, or otherwise prevent the collection of
taxes believed to be owing, Spies v. United States, supra at 499.
Courts have relied on a number of indicia or badges of fraud
in deciding whether to sustain the Commissioner’s determinations
with respect to the additions to tax for fraud. Although no
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