Darrell L. Gaines - Page 20

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          return filed for each of those years.  In addition to the amended           
          returns, an underpayment of tax for each year is further                    
          demonstrated by respondent’s net worth analysis, the validity of            
          which is supported by evidence in the record that establishes               
          both the existence of a likely source of unreported income (i.e.,           
          Grand Video), and the implausibility of petitioner’s claim to the           
          existence of a cash hoard not taken into account in the net worth           
          analysis.  See Parks v. Commissioner, supra at 661.  Respondent             
          has met his burden of establishing an underpayment of tax for               
          each year in issue by clear and convincing evidence.                        
               Respondent must also establish that a portion of the                   
          underpayment of tax for each year is due to fraud.  Fraud will be           
          found if, at the time petitioner filed his return for each year             
          in issue, he “intended to evade taxes known to be owing by                  
          conduct intended to conceal, mislead, or otherwise prevent the              
          collection of such taxes.”  Rowlee v. Commissioner, 80 T.C. 1111,           
          1123 (1983).                                                                
               Because fraudulent intent is seldom established by direct              
          evidence, it may be reasonably inferred from circumstantial                 
          evidence, including evidence of a taxpayer’s course of conduct.             
          See United States v. Walton, 909 F.2d 915, 926 (6th Cir. 1990);             
          Rowlee v. Commissioner, supra; Stone v. Commissioner, 56 T.C.               
          213, 224 (1971).  Conduct that may indicate fraudulent intent,              
          commonly referred to as “badges of fraud”, includes, but is not             






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