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          and reasonable inferences properly to be drawn therefrom.  See              
          Otsuki v. Commissioner, 53 T.C. 96, 106 (1969).  Any conduct, the           
          likely effect of which would be to mislead or to conceal may                
          establish an affirmative act of evasion.  See Spies v. United               
          States, 317 U.S. 492, 499 (1943).                                           
               The courts have relied upon a number of indicia of fraud in            
          deciding whether an underpayment of tax is due to fraud.  While             
          no single factor is necessarily sufficient to establish fraud,              
          the existence of several indicia is persuasive circumstantial               
          evidence of fraud.  See Petzoldt v. Commissioner, 92 T.C. 661,              
          700 (1989).                                                                 
               Respondent argues that the following factors or “badges” of            
          fraud are present in this case:  (1) A substantial and consistent           
          understatement of income; (2) false statements made by                      
          petitioners during their interview with respondent’s agents; (3)            
          extensive dealings in cash; (4) failure to maintain adequate                
          records; and (5) failure to furnish their return preparer with              
          accurate information.                                                       
                    1.  Substantial and Consistent Understatement of                  
                         Income                                                       
               The consistent failure to report substantial amounts of                
          income over a number of years, standing alone, is effective                 
          evidence of fraudulent intent.  See Schwarzkopf v. Commissioner,            
          246 F.2d 731, 734 (3d Cir. 1957), affg. and remanding on another            
          issue T.C. Memo. 1956-155.  In this case, there is a substantial            
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