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Although petitioner does not dispute that his tax lia-
bility for each of the years 1993, 1994, and 1995 exceeds his
prepayment credits for each of those years, he alleges on brief
that "Respondent has not established * * * an underpayment of
tax" for 1992. We disagree. Although petitioner initially
claimed that there was an overpayment for 1992, he ultimately
conceded before the trial in this case that there is no over-
payment for 1992. Moreover, the record establishes, and we have
determined, that, after taking into account the concessions by
the parties with respect to 1992, petitioner has a tax liability
for that year which is in excess of the prepayment credits that
he has for that year (viz., estimated tax payments totaling
$6,300).
To prove fraudulent intent, respondent must prove by clear
and convincing evidence that the taxpayer intended to evade tax
that he or she believed to be owing by conduct intended to
conceal, mislead, or otherwise prevent the collection of such
tax. See Stoltzfus v. United States, 398 F.2d 1002, 1004 (3d
Cir. 1968); Parks v. Commissioner, 94 T.C. 654, 661 (1990);
Laurins v. Commissioner, 889 F.2d 910, 913 (9th Cir. 1989), affg.
Norman v. Commissioner, T.C. Memo. 1987-265. The existence of
fraud is a question of fact to be resolved upon consideration of
the entire record. See DiLeo v. Commissioner, 96 T.C. 858, 874
(1991), affd. 959 F.2d 16 (2d Cir. 1992); Recklitis v. Commis-
sioner, 91 T.C. 874, 909 (1988); Gajewski v. Commissioner, 67
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