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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, 53 T.C. 96, 105-106 (1969).
Courts have developed several indicia of fraud, or "badges
of fraud", which include: (1) Understatement of income, (2)
inadequate books and 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. Douge v. Commissioner, 899 F.2d 164, 168 (2d Cir.
1990); Bradford v. Commissioner, supra at 307; Recklitis v.
Commissioner, 91 T.C. 874, 910 (1988). This list is
nonexclusive. Miller v. Commissioner, 94 T.C. 316, 334 (1990).
The strongest evidence of fraud in this case consists of the
false documents that petitioner husband prepared and solicited to
make it appear that petitioners expressed an interest in the
Pleasant Hill and Skyland properties within the identification
period. Submitting false documents to the IRS is an indication
of fraud. Stephenson v. Commissioner, 79 T.C. 995, 1007 (1982),
affd. 748 F.2d 331 (6th Cir. 1984); Association Cable TV, Inc. v.
Commissioner, T.C. Memo. 1995-596.
Petitioners contend that their attorney Mr. Clack advised
them to obtain the false documents. Petitioners maintain that
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