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fraudulent intent. Korecky v. Commissioner, 781 F.2d 1566 (11th
Cir. 1986), affg. T.C. Memo. 1985-63. Indicia of fraudulent
intent include the following: A pattern of consistent
underreporting of income, Parks v. Commissioner, supra at 664;
the filing of false documents, Stephenson v. Commissioner, 79
T.C. 995, 1007 (1982), affd. 748 F.2d 331 (6th Cir. 1984);
destruction of records, Prokop v. Commissioner, 254 F.2d 544 (7th
Cir. 1958), affg. T.C. Memo. 1957-75; inadequate and incomplete
records, failure to file tax returns, implausible or inconsistent
explanations of behavior, concealment of assets, and failure to
cooperate with tax authorities, Bradford v. Commissioner, 796
F.2d 303, 307 (9th Cir. 1986), affg. T.C. Memo. 1984-601.
If the Commissioner establishes that any portion of the
underpayment is attributable to fraud, then the entire
underpayment for that tax year shall be treated as attributable
to fraud, unless the taxpayer can establish that a portion is not
attributable to fraud. Sec. 6663(b). The term “underpayment” is
defined by section 6664(a) to mean the amount by which any tax
imposed by this title exceeds the excess of (1) the sum of (A)
the amount shown as the tax by the taxpayer on his return, plus
(B) amounts not so shown previously assessed (or collected
without assessment), over (2) the amount of rebates made. Estate
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