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income that were not reported on his 1984, 1985, 1986, and 1987
tax returns. Indeed, before trial petitioner conceded
adjustments in his income tax in the respective amounts of
$48,159, $131,545, $159,535, and $71,946 for the years in
question. Thus, with respect to each of petitioner's taxable
years in issue, we hold that respondent has met her burden on the
first prong of the two-prong test for fraud.
2. Fraudulent Intent
Fraud is defined as an intentional wrongdoing designed to
evade tax believed to be owing. Powell v. Grandquist, 252 F.2d
56 (9th Cir. 1958); Miller v. Commissioner, 94 T.C. 316, 332
(1990). The existence of fraud is a question of fact.
Gajewski v. Commissioner, 67 T.C. 181, 199 (1976), affd. without
published opinion 578 F.2d 1383 (8th Cir. 1978). Fraud is never
presumed or imputed; it must be established by independent
evidence that establishes a fraudulent intent on the taxpayer's
part. Otsuki v. Commissioner, 53 T.C. 96, 106 (1969). For
respondent to prevail, she must show that petitioner intended to
conceal, mislead, or otherwise prevent the collection of taxes.
Korecky v. Commissioner, 781 F.2d 1566, 1568 (11th Cir. 1986),
affg. per curiam T.C. Memo. 1985-63; Stoltzfus v. United States,
supra at 1004; Webb v. Commissioner, 394 F.2d 366, 377 (5th Cir.
1968), affg. T.C. Memo. 1966-81; Rowlee v. Commissioner, supra at
1123. Because direct proof of a taxpayer's intent is rarely
available, fraud may be proven by circumstantial evidence, and
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