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Castillo v. Commissioner, 84 T.C. 405, 408 (1985); Stone v.
Commissioner, 56 T.C. 213, 220 (1971). To meet this burden,
respondent must establish that an underpayment of tax exists and
that petitioner intended to evade taxes known to be owing by
conduct intended to conceal, mislead, or otherwise prevent the
collection of such taxes. Grossman v. Commissioner, supra
at 277; Stoltzfus v. United States, 398 F.2d 1002, 1004 (3d Cir.
1968); Parks v. Commissioner, 94 T.C. 654, 660 (1990); Recklitis
v. Commissioner, 91 T.C. 874, 909 (1988); Castillo v.
Commissioner, supra at 408-409; Rowlee v. Commissioner, 80 T.C.
1111, 1123 (1983); Acker v. Commissioner, 26 T.C. 107, 112
(1956).
Respondent need not establish that tax evasion was
petitioner’s primary motivation but must show that a “‘tax-
evasion motive’” played a part in petitioner’s conduct, including
conduct designed to conceal another crime. Recklitis v.
Commissioner, supra at 909 (quoting Worcester v. Commissioner,
370 F.2d 713, 717 (1st Cir. 1966), vacating T.C. Memo. 1965-199).
The existence of fraud is a question of fact to be resolved
upon consideration of the entire record. Castillo v.
Commissioner, supra at 409; Rowlee v. Commissioner, supra at
1123; Gajewski v. Commissioner, 67 T.C. 181, 199 (1976), affd.
without published opinion 578 F.2d 1383 (8th Cir. 1978). Fraud
is never imputed or presumed; it must be established by
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