- 26 -
Gajewski v. Commissioner, supra at 200. The taxpayer's
entire course of conduct may establish the requisite
fraudulent intent. See Spies v. United States, 317 U.S.
492 (1943); Castillo v. Commissioner, supra; Gajewski v.
Commissioner, supra; Stone v. Commissioner, supra at 223-
224.
Over the years, courts have developed a nonexclusive
list of factors that demonstrate fraudulent intent. These
"badges of fraud" include: (1) Understating income; (2)
maintaining inadequate records; (3) failing to file tax
returns; (4) implausible or inconsistent explanations of
behavior; (5) concealment of income or assets; (6) failing
to cooperate with tax authorities; (7) engaging in illegal
activities; (8) an intent to mislead which may be inferred
from a pattern of conduct; (9) lack of credibility of the
taxpayer's testimony; (10) filing false documents; and (11)
dealing in cash. See Spies v. United States, supra at 499;
Douge v. Commissioner, 899 F.2d 164, 168 (2d Cir. 1990);
Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th
Cir. 1986), affg. T.C. Memo. 1984-601; Recklitis v.
Commissioner, supra at 910. Although no single factor is
necessarily sufficient to establish fraud, the combination
of a number of factors may be persuasive evidence of fraud.
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