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of establishing an underpayment by either: (1) Proving a likely
source of the unreported income or (2) disproving the nontaxable
source(s) that the taxpayer alleges for the unreported income.
Parks v. Commissioner, supra at 661.
On the instant record, we find that respondent has estab-
lished by clear and convincing evidence a likely source of
petitioner’s unreported income for each of the years at issue,
viz., the various Schedule C and other income-producing activi-
ties in which petitioner engaged during each of those years.106
On the record before us, we find that respondent has established
by clear and convincing evidence that there was an underpayment
of petitioner’s tax for each of the years 1991 through 1993.
Fraudulent Intent
To prove fraudulent intent, the Commissioner must prove by
clear and convincing evidence that the taxpayer intended to evade
tax, which he or she believed to be owing, by conduct intended to
conceal, mislead, or otherwise prevent the collection of such
tax. Laurins v. Commissioner, 889 F.2d 910, 913 (9th Cir. 1989),
affg. Norman v. Commissioner, T.C. Memo. 1987-265; Parks v.
Commissioner, supra at 661. The existence of fraud is a question
of fact to be resolved upon consideration of the entire record.
DiLeo v. Commissioner, supra at 874; Gajewski v. Commissioner, 67
106Petitioner’s failure to contest certain amounts of unre-
ported income determined for 1991 and 1993, certain amounts of
claimed cost of goods sold disallowed for 1991, 1992, and 1993,
and certain amounts of claimed Schedule C expenses disallowed for
1991 and 1992, which we have found constitutes an abandonment by
petitioner of those items, also establishes by clear and convinc-
ing evidence that an underpayment exists for each of the years at
issue.
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