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Commissioner, 79 T.C. 888, 930 (1982). The existence of fraud is
a question of fact to be resolved from the entire record.
Gajewski v. Commissioner, 67 T.C. 181, 199 (1976), affd. without
published opinion 578 F.2d 1383 (8th Cir. 1978). Because direct
proof of a taxpayer's intent is rarely available, fraud may be
proven by circumstantial evidence and reasonable inferences may
be drawn from the relevant facts. Spies v. United States, 317
U.S. 492, 499 (1943); Stephenson v. Commissioner, 79 T.C. 995,
1006 (1982), affd. 748 F.2d 331 (6th Cir. 1984). A taxpayer's
entire course of conduct can be indicative of fraud. Stone v.
Commissioner, 56 T.C. 213, 223-224 (1971); Otsuki v.
Commissioner, 53 T.C. 96, 105-106 (1969). The sophistication,
education, and intelligence of the taxpayer are relevant to
determining fraudulent intent. See Niedringhaus v. Commissioner,
99 T.C. 202, 211 (1992); Stephenson v. Commissioner, supra at
1006; Iley v. Commissioner, 19 T.C. 631, 635 (1952).
Over the years, courts have developed a nonexclusive list of
factors that demonstrate fraudulent intent. These badges of
fraud include: (1) Understating income, (2) maintaining
inadequate records, (3) implausible or inconsistent explanations
of behavior, (4) concealment of income or assets, (5) failing to
cooperate with tax authorities, (6) engaging in illegal
activities, (7) an intent to mislead which may be inferred from a
pattern of conduct, (8) lack of credibility of the taxpayer's
testimony, (9) filing false documents, (10) awareness of the
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