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not mean that petitioner underpaid his taxes for purposes of the
additions to tax for fraud. See Parks v. Commissioner, 94 T.C.
654, 660-661 (1990); Fields v. Commissioner, T.C. Memo. 1996-425.
Following our careful review of the record, we conclude that
respondent has clearly and convincingly proven that petitioner
underpaid his taxes for each year in issue. See sec. 6653(c)(1)
(an “underpayment” generally is the same as a “deficiency” under
sec. 6211). The record clearly convinces us that petitioner had
gross income in 1986 and 1987, and that he should have filed
returns and reported that income. The first prong is satisfied.
As to the second prong, fraud is defined as an intentional
wrongdoing designed to evade tax believed to be owing. See
Miller v. Commissioner, 94 T.C. 316, 332 (1990). The existence
of fraud is a question of fact. See 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. See Otsuki v.
Commissioner, 53 T.C. 96, 106 (1969). For respondent to prevail,
he must show that petitioner intended to conceal, mislead, or
otherwise prevent the collection of taxes. See 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),
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