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resolved on the basis of the entire record. DiLeo v.
Commissioner, supra at 874; Gajewski v. Commissioner, 67 T.C.
181, 191 (1976), affd. without published opinion 578 F.2d 1383
(8th Cir. 1978). Fraud is not to be imputed or presumed. It
must be affirmatively established by clear and convincing
evidence. Beaver v. Commissioner, 55 T.C. 85, 92 (1970). The
taxpayer's entire course of conduct may establish the requisite
fraudulent intent. DiLeo v. Commissioner, supra at 874; Stone v.
Commissioner, 56 T.C. 213, 223-224 (1971). Because direct
evidence of the taxpayer's fraudulent intent is rarely available,
fraud may be proven by circumstantial evidence and reasonable
inferences drawn from the facts. DiLeo v. Commissioner, supra at
874; Rowlee v. Commissioner, supra at 1123.
Courts have relied on a number of indicia of fraud in
deciding whether to sustain the Commissioner's determinations
with respect to fraud. Although no single factor is necessarily
sufficient to establish fraud, the existence of several indicia
is persuasive circumstantial evidence of fraud. Petzoldt v.
Commissioner, 92 T.C. 661, 700 (1989). In Bradford v.
Commissioner, 796 F.2d 303, 307 (9th Cir. 1986), affg. T.C. Memo.
1984-601, the Court of Appeals for the Ninth Circuit gave a
nonexclusive list of circumstantial evidence that may give rise
to a finding of fraudulent intent. Badges of fraud include (1)
understatement of income, (2) inadequate records, and (3) dealing
in cash. Id. A failure to be forthright with one's return
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