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proof of the taxpayer's intent is rarely available. The
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). A
pattern of consistent underreporting of income for a number of
years, when accompanied by other circumstances showing an intent
to conceal, justifies the inference of fraud as to each of the
years. Holland v. Commissioner, 348 U.S. 121, 137 (1954); Otsuki
v. Commissioner, supra.
Under section 61, gross income includes "all income from
whatever source derived." Gross income includes funds derived
from legal and illegal sources. Rutkin v. United States, 343
U.S. 130 (1952). Where a taxpayer keeps no books and records, or
the taxpayer fails to file a return from which his income tax
liability can be assessed, the IRS may reconstruct the taxpayer's
income. Sec. 446(b); Moore v. Commissioner, 722 F.2d 193 (5th
Cir. 1984), affg. T.C. Memo. 1983-20. The IRS has great latitude
in reconstruction methods. Giddio v. Commissioner, 54 T.C. 1530,
1532-1534 (1970). As a general rule, the computation of taxable
income is made under the method of accounting regularly employed
by the taxpayer or, if no method of accounting has been used by
the taxpayer, made under such method as, in the opinion of
respondent, clearly reflects income. Sec. 446(b); Moore v.
Commissioner, supra; Giddio v. Commissioner, supra. This Court
has approved the use of "trick sheets" to reconstruct a
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