- 17 -
Niedringhaus v. Commissioner, supra at 211. Although no single
factor is necessarily sufficient to establish fraud, the exis-
tence of several indicia constitutes persuasive circumstantial
evidence of fraud. See Bradford v. Commissioner, supra at 307;
Petzoldt v. Commissioner, supra at 700.
The record in this case is replete with indicia of fraud on
the part of Ms. Drummond and on the part of Mr. Drummond, includ-
ing the following. Ms. Drummond, a college graduate and a
certified management accountant, was fully aware of the require-
ment to report income and to file tax returns for the years at
issue. She nonetheless did not report a substantial amount of
income in her 1983 return and did not report any income for 1984
because she did not file a return for that year. Ms. Drummond
was the bookkeeper and the comptroller of ABC and vice president
of E.D.U.C. In those supervisory roles, Ms. Drummond wrote
certain checks or caused certain checks to be written for ABC to
herself and to Mr. Drummond, the amounts of which they did not
report as income for the years at issue. She also caused herself
to be removed from ABC's payroll and directed ABC's employees not
to issue a Form 1099 to her or to Mr. Drummond. Ms. Drummond
thereby took acts designed to conceal the income that was paid to
her and to Mr. Drummond. Ms. Drummond willfully subscribed to
and filed a false tax return for 1983 and failed to file a tax
return for 1984, for which she was convicted under sections
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