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petitioner's primary motivation was tax evasion but must
show that a "tax-evasion motive played any part" in his
conduct, including conduct designed to conceal another
crime. See Recklitis v. Commissioner, supra at 909
(quoting Worcester v. Commissioner, 370 F.2d 713, 717
(1st Cir. 1966), vacating T.C. Memo. 1965-199).
The existence of fraud is a question of fact to
be resolved upon consideration of the entire record.
See Castillo v. Commissioner, supra at 409; Rowlee v.
Commissioner, supra at 1123; Gajewski v. Commissioner, 67
T.C. 181, 199 (1976), affd. without published opinion 578
F.2d 1383 (8th Cir. 1978). Fraud will never be imputed or
presumed, but must be established by independent evidence.
See Recklitis v. Commissioner, supra at 910; Castillo v.
Commissioner, supra; Beaver v. Commissioner, 55 T.C. 85,
92 (1970). However, because direct proof of a taxpayer's
intent is rarely available, fraud may be proved by
circumstantial evidence, including the implausibility of
the taxpayer's explanations. See Boyett v. Commissioner,
204 F.2d 205, 208 (5th Cir. 1953), affg. a Memorandum
Opinion of this Court dated Mar. 14, 1951; Castillo v.
Commissioner, supra; Stephenson v. Commissioner, 79 T.C.
995, 1005-1006 (1982), affd. 748 F.2d 331 (6th Cir. 1984);
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