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intended to evade taxes that he or she believed to be owing by
conduct intended to conceal, mislead, or otherwise prevent the
collection of such taxes. Stoltzfus v. United States, 398 F.2d
1002, 1004 (3d Cir. 1968); Parks v. Commissioner, 94 T.C. 654,
661 (1990). The existence of fraudulent intent 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). Although
fraudulent intent is never presumed, it may be established by
circumstantial evidence because direct proof of the taxpayer's
intent is rarely available. Petzoldt v. Commissioner, 92 T.C.
661, 699 (1989); Rowlee v. Commissioner, 80 T.C. 1111, 1123
(1983). The taxpayer's entire course of conduct may establish
the requisite fraudulent intent. Rowlee v. Commissioner, supra
at 1123; Otsuki v. Commissioner, 53 T.C. 96, 106 (1969).
The courts have established a number of badges of fraud from
which fraudulent intent may be inferred. Those badges include:
(1) Substantial and consistent understatement of income,
(2) failure to maintain adequate records, (3) incomplete and
erroneous information provided to tax return preparer or book-
keeper, (4) destruction of books and records, (5) implausible
explanation of behavior, (6) lack of credibility of the tax-
payer's testimony, and (7) failure to cooperate with tax authori-
ties. See Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th
Cir. 1986), affg. T.C. Memo. 1984-601; Toussaint v. Commissioner,
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