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that, for the taxable year 1992, petitioner received $15,000 in
embezzlement income, $1,381 in wage income, and $11,000 in
taxable cash receipts. Based on the admitted facts, we sustain
the deficiencies for 1990, 1991, and 1992, as determined in the
notice of deficiency.
B. Additions to Tax for Fraud
The second issue is whether petitioner is liable for the
additions to tax for fraud under section 6651(f). Section
6651(f) provides for a maximum addition to tax of 75 percent if
any failure to file is fraudulent.
The additions to tax in the case of fraud are civil
sanctions provided primarily as a safeguard for the protection of
the revenue and to reimburse the Government for the heavy expense
of investigation and for the loss resulting from the taxpayer's
fraud. Helvering v. Mitchell, 303 U.S. 391, 401 (1938). Respon-
dent has the burden of making a clear and convincing showing that
the failure to file a Federal income tax return for each year was
due to fraud. See Rule 142(b); sec. 7454(a). Fraud is
intentional wrongdoing on the part of the taxpayer with the
specific purpose of evading a tax believed to be owing. Petzoldt
v. Commissioner, 92 T.C. 661, 698 (1989). Fraud is shown by
proof that the taxpayer intended to conceal, mislead, or other-
wise prevent the collection of his taxes. Stoltzfus v. United
States, 398 F.2d 1002, 1004 (3d Cir. 1968); Webb v. Commissioner,
394 F.2d 366, 377 (5th Cir. 1968), affg. T.C. Memo. 1966-81. In
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