- 19 -
1984-601; Lord v. Commissioner, 525 F.2d 741, 745 (9th Cir.
1975), affg. in part and revg. in part 60 T.C. 199 (1973); Ruark
v. Commissioner, 449 F.2d 311, 312-313 (9th Cir. 1971), affg. per
curiam T.C. Memo. 1969-48; Niedringhaus v. Commissioner, supra at
211; Parks v. Commissioner, supra at 664-665; Miller v. Com-
missioner, 94 T.C. 316, 334 (1990); Recklitis v. Commissioner,
supra at 910; Castillo v. Commissioner, 84 T.C. 405, 409 (1985).
In addition, the taxpayer's background, including the sophistica-
tion, experience, and education of the taxpayer, and the context
of the events in question may be considered circumstantial
evidence of fraud. See Plunkett v. Commissioner, 465 F.2d 299,
303 (7th Cir. 1972), affg. T.C. Memo. 1970-274; Niedringhaus v.
Commissioner, supra at 211. Although no single factor is neces-
sarily sufficient to establish fraud, the existence of several
indicia constitutes persuasive circumstantial evidence of fraud.
See Bradford v. Commissioner, supra at 307; Petzoldt v. Commis-
sioner, supra at 700.
The record in this case is replete with indicia of fraud by
petitioner. Petitioner, an attorney in private practice who also
served during the 1980's as a part-time judge of various local
courts in and around San Diego, California, was fully aware of
the requirement to report income and to file returns for the
years at issue. She also knew about the possible criminal
consequences for failing to file a return. Nonetheless, pe-
titioner did not report any income or file a return for any of
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