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for each of the years. See Drieborg v. Commissioner, 225 F.2d
216, 219-220 (6th Cir. 1955), affg. in part and revg. in part a
Memorandum Opinion of this Court dated Feb. 24, 1954.
A. Underpayment of Taxes
Based on the evidence presented and our previous analysis,
we find that respondent has clearly and convincingly established
that petitioner understated his taxable income by $47,75035 in
1988, $88,40436 in 1989, $77,14937 in 1990, $18,25838 in 1991, and
$20,08339 in 1992. Petitioner underpaid his taxes for each year
in issue.
B. Fraudulent Intent
Respondent must prove that a portion of the underpayment is
attributable to the fraudulent intent of petitioner. Fraud is
the intentional wrongdoing motivated by a specific purpose to
evade a tax known or believed to be owing. See Stolzfus v.
United States, 398 F.2d 1002, 1004 (3d Cir. 1968). The existence
of fraud is a question of fact to be resolved upon consideration
of the entire record. See Gajewski v. Commissioner, 67 T.C. 181,
35See appendix A or F.
36See appendix B or G.
37See appendix C or H.
38See appendix D or I.
39See appendix E or J.
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