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offered no evidence to corroborate his testimony, and, without
more, petitioner's explanation is implausible and not credible.
Respondent also determined that petitioner's underpayment of
income tax for 1989 was due to fraud. The penalty in the case of
fraud is a civil sanction provided primarily as a safeguard for
the protection of the revenue and to reimburse the Government for
the heavy expense of investigation and the loss resulting from
the taxpayer's fraud. Helvering v. Mitchell, 303 U.S. 391, 401
(1938). Respondent has the burden of proving, by clear and
convincing evidence, an underpayment for 1989 and that some part
of an underpayment for that year was due to fraud. Sec. 7454(a);
Rule 142(b). If respondent establishes that any portion of the
underpayment is attributable to fraud, the entire underpayment is
treated as attributable to fraud and subjected to a 75-percent
penalty unless the taxpayer establishes that some part of the
underpayment is not attributable to fraud. Sec. 6663(b).
Respondent's burden is met if it is shown that the taxpayer
intended to conceal, mislead, or otherwise prevent the collection
of taxes. Rowlee v. Commissioner, 80 T.C. 1111, 1123 (1983).
The existence of fraud is a question of fact to be resolved
upon consideration of the entire record. King's Court Mobile
Home Park, Inc. v. Commissioner, 98 T.C. 511, 516 (1992). Fraud
will never be presumed. Beaver v. Commissioner, 55 T.C. 85, 92
(1970). Fraud may, however, be proved by circumstantial evidence
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