-42-
748 F.2d 331 (6th Cir. 1984). 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, supra at 105-106. The intent to conceal or mislead
may be inferred from a pattern of conduct. See Spies v. United
States, supra at 499.
Courts have relied on several indicia of fraud in
considering the fraud addition in tax cases. Although no single
factor may necessarily be sufficient to establish fraud, the
existence of several indicia may be persuasive circumstantial
evidence of fraud. Solomon v. Commissioner, 732 F.2d 1459, 1461
(6th Cir. 1984), affg. per curiam T.C. Memo. 1982-603; Beaver v.
Commissioner, supra at 93.
Circumstantial evidence that may give rise to a finding of
fraudulent intent includes: (1) Understatement of income,
(2) inadequate records, (3) failure to file tax returns,
(4) implausible or inconsistent explanations of behavior,
(5) concealment of assets, (6) failure to cooperate with tax
authorities, (7) filing false Forms W-4, (8) failure to make
estimated tax payments, (9) dealing in cash, (10) engaging in
illegal activity, and (11) attempting to conceal illegal
activity. Bradford v. Commissioner, 796 F.2d 303, 307 (9th Cir.
1986), affg. T.C. Memo. 1984-601; see Douge v. Commissioner, 899
F.2d 164, 168 (2d Cir. 1990). These "badges of fraud" are
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