- 33 -                                                  
            it by clear and convincing evidence.  See Rule 142(b).  Thus, we                           
            do not bootstrap a finding of fraud upon a taxpayer’s failure to                           
            disprove the Commissioner’s deficiency determination.  See Parks                           
            v. Commissioner, 94 T.C. 654, 660-661 (1990).                                              
                  In order to satisfy this burden, respondent must show (1)                            
            that an underpayment exists, and (2) that the taxpayer intended                            
            to evade taxes known to be owing by conduct intended to conceal,                           
            mislead, or otherwise prevent the collection of taxes.  See id.                            
                  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).  Fraud is never presumed                            
            and must be established by independent evidence of fraudulent                              
            intent.  See Edelson v. Commissioner, supra.  Fraud may be shown                           
            by circumstantial evidence because direct evidence of the                                  
            taxpayer’s fraudulent intent is seldom available.  See Gajewski                            
            v. Commissioner, 67 T.C. 181, 199 (1976), affd. without published                          
            opinion 578 F.2d 1383 (8th Cir. 1978).  The taxpayer’s entire                              
            course of conduct may establish the requisite fraudulent intent.                           
            See Stone v. Commissioner, 56 T.C. 213, 224 (1971).                                        
                  To decide whether the fraud penalty is applicable, courts                            
            consider several indicia of fraud, or “badges of fraud”, which                             
            include: (1) Understatement of income; (2) inadequate books and                            
            records; (3) failure to file tax returns; (4) implausible or                               
            inconsistent explanations of behavior; (5) concealment of assets;                          
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