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taxes. Stoltzfus v. United States, 398 F.2d 1002, 1004
(3d Cir. 1968); Rowlee v. Commissioner, 80 T.C. 1111,
1123 (1983). The issue is one of fact to be determined
upon a consideration of the entire record. Rowlee v.
Commissioner, supra; Beaver v. Commissioner, 55 T.C. 85,
92 (1970).
In view of the fact that fraudulent intent can
seldom be established by direct proof of the taxpayer's
intention, fraud is usually established by drawing
inferences from the taxpayer’s entire course of conduct.
Parks v. Commissioner, 94 T.C. 654, 664 (1990); Estate of
Beck v. Commissioner, 56 T.C. 297, 363 (1971). The courts
have developed several indicia or "badges" of fraudulent
behavior. These “badges of fraud” include conduct such
as consistently understating income, Estate of Upshaw v.
Commissioner, 416 F.2d 737 (7th Cir. 1969); Parks v.
Commissioner, supra; failing to cooperate with tax
authorities, Zell v. Commissioner, 763 F.2d 1139, 1146
(10th Cir. 1985), affg. T.C. Memo. 1984-152; and any other
conduct likely to mislead or conceal, see Estate of
Schneider v. Commissioner, 29 T.C. 940, 954-955 (1958).
We note that since petitioner is a corporation, it can
act only through its officers. Federbush v. Commissioner,
34 T.C. 740, 749 (1960), affd. 325 F.2d 1 (2d Cir. 1963).
In this case, respondent has proven that $127,889 of
petitioner's income in 1990 was diverted to the personal
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