Zacharia and Rawa Hadri - Page 7




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          amount equal to 75 percent of the underpayment which is                     
          attributable to fraud shall be added to the tax.  While                     
          respondent ultimately has the burden of proving fraud, it can               
          seldom be shown by direct proof of the taxpayer’s intention.                
          Spies v. United States, 317 U.S. 492, 499 (1943).  However, fraud           
          can be established by circumstantial evidence and by reasonable             
          inferences drawn from the taxpayer’s entire course of conduct.              
          Id.  Such inferences may be drawn from the so-called badges of              
          fraud including, but not limited to, understated or unreported              
          income, inadequate records, intentional concealment of income and           
          assets, and failure to cooperate with taxing authorities.                   
          Bradford v. Commissioner, 796 F.2d 303 (9th Cir. 1986), affg.               
          T.C. Memo. 1984-601.                                                        
               Based on the evidence, including the facts established under           
          Rule 91(f) and the evidence at trial, we find that petitioners              
          intended to conceal, mislead, or otherwise prevent the collection           
          of their taxes.  Petitioners failed to report a substantial                 
          amount of income.  Petitioners concealed two bank accounts with             
          $513,614 in taxable deposits from their own representative and              
          respondent.  Petitioners kept and maintained inadequate records             
          which did not reflect all income or expenses.  Petitioners                  
          concealed a substantial business activity from their own                    
          representative and from respondent.  In an attempt to explain               
          this concealment, petitioners claimed that the activity had                 






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