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The existence of fraud is a question of fact to be resolved
from the entire record. See DiLeo v. Commissioner, 96 T.C. 858,
874 (1991), affd. 959 F.2d 16 (2d Cir. 1992). Fraud may be
proven by circumstantial evidence, and reasonable inferences may
be drawn from the relevant facts. See Spies v. United States,
317 U.S. 492, 499 (1943); Stephenson v. Commissioner, 79 T.C.
995, 1006 (1982), affd. 748 F.2d 331 (6th Cir. 1984). 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, supra at 499; Zell v. Commissioner, 763 F.2d
1139, 1145-1146 (10th Cir. 1985), affg. T.C. Memo. 1984-152. A
pattern of consistent underreporting of income, particularly when
accompanied by other circumstances exhibiting an intent to
conceal, justifies the inference of fraud. See Parks v.
Commissioner, supra at 664.
Petitioner understated interest income and claimed false
deductions for mortgage interest payments, resulting in the
consistent underreporting of income tax liabilities for 5 years.
Petitioner intentionally falsified computer records of the Bank
and misled respondent with respect to his correct income tax
liabilities. Petitioner signed the returns for each year in
issue with full knowledge that he was underreporting his taxable
income. As a result of his actions, petitioner was criminally
convicted for his underreporting activities, and petitioner
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