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Under section 6653(b) respondent has the burden of proving
by clear and convincing evidence that there is an underpayment of
tax and that some part of the underpayment was due to fraud. See
sec. 7454(a); Rule 142(b). Respondent must show that petitioner
intended to evade taxes known to be owing by conduct intended to
conceal, mislead, or otherwise prevent the collection of such
taxes. Rowlee v. Commissioner, 80 T.C. 1111, 1123 (1983). Where
a taxpayer claims ignorance of the law or a good-faith belief
that he was not violating any of the provisions of the tax laws,
the Commissioner must negate that claim by clear and convincing
evidence. Cheek v. United States, 498 U.S. 192, 202 (1991); see
also Niedringhaus v. Commissioner, 99 T. C. 202, 217 (1992). For
purposes of the section 6653(b)(2) interest computation,
respondent must also prove the portion of the underpayment
attributable to fraud. Sec. 6653(b)(2); DiLeo v. Commissioner,
96 T.C. 858, 873 (1991), affd. 959 F.2d 16 (2d Cir. 1992).
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.
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