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$38,334.50 that resulted in the underpayment. Accordingly,
pursuant to section 6653(b), respondent has proven that an
underpayment of tax exists for the year in issue. We now must
decide whether petitioner intended to conceal, mislead, or
otherwise prevent the collection of such taxes. Rowlee v.
Commissioner, supra at 1123, and cases cited therein.
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). Fraud will never be
presumed. Beaver v. Commissioner, 55 T.C. 85, 92 (1970). Fraud
may, however, be proved by circumstantial evidence, because
direct proof of the taxpayer's intent is rarely available.
Rowlee v. Commissioner, supra. The taxpayer's entire course of
conduct may establish the requisite fraudulent intent. Stone v.
Commissioner, 56 T.C. 213, 223-224 (1971). The intent to conceal
or mislead may be inferred from a pattern of conduct. See Spies
v. United States, 317 U.S. 492, 499 (1943). Over the years, this
Court has developed a nonexclusive list of the various kinds of
circumstantial evidence that may support a finding of fraud. See
Niedringhaus v. Commissioner, 99 T.C. 202, 211 (1992) (citing
Bradford v. Commissioner, 796 F.2d 303, 307 (9th Cir. 1986),
affg. T.C. Memo. 1984-601).
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