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underpayments in 1994 and 1995. The only remaining issue is
whether Mr. Cordes intended to evade the taxes on these items
known to be owing by conduct intended to conceal, mislead, or
otherwise prevent collection of taxes. Stoltzfus v. United
States, 398 F.2d 1002, 1004 (3d Cir. 1968); Rowlee v.
Commissioner, 80 T.C. 1111, 1123 (1983). The issue is one of
fact to be determined upon a consideration of the entire record.
Rowlee v. Commissioner, supra at 1123; Beaver v. Commissioner, 55
T.C. 85, 92 (1970). For the reasons discussed below, we hold for
respondent.
Fraudulent intent can seldom be established by direct proof
of the taxpayer’s intention; therefore, fraud is usually
established by drawing inferences from the taxpayer’s entire
course of conduct. Parks v. Commissioner, 94 T.C. 654, 664
(1990); Estate of Beck v. Commissioner, 56 T.C. 297, 363 (1971).
The courts have developed several indicia or “badges” of
fraudulent behavior. Circumstantial evidence which may give rise
to a finding of fraudulent intent includes: (1) Understatement
of income; (2) inadequate records; (3) failure to file tax
returns; (4) implausible or inconsistent explanations of
behavior; (5) concealment of assets; (6) failure to cooperate
with tax authorities; (7) filing false documents; (8) failure to
make estimated tax payments; (9) dealing in cash; (10) engaging
in illegal activity; and (11) attempting to conceal illegal
activity. Bradford v. Commissioner, 796 F.2d 303, 307-308 (9th
Cir. 1986), affg. T.C. Memo. 1984-601; Clayton v. Commissioner,
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