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(1943); Korecky v. Commissioner, supra at 1568; Rowlee v.
Commissioner, supra at 1123. Although fraud may not be found
under "circumstances which at the most create only suspicion",
Petzoldt v. Commissioner, supra at 700, the intent to defraud may
be inferred from any conduct the likely effect of which would be
to conceal, mislead, or otherwise prevent the collection of taxes
believed to be owing, Spies v. United States, supra at 499.
Courts have relied on a number of indicia or badges of fraud
in deciding whether to sustain the Commissioner’s determinations
with respect to the additions to tax for fraud. Although no
single factor may be necessarily sufficient to establish fraud,
the existence of several indicia may be persuasive circumstantial
evidence of fraud. Solomon v. Commissioner, 732 F.2d 1459, 1461
(6th Cir. 1984), affg. per curiam T.C. Memo. 1982-603; Beaver v.
Commissioner, supra at 93.
Circumstantial evidence that may give rise to a finding of
fraudulent intent includes: Understatement of income; inadequate
records; failure to file tax returns; concealment of assets;
failure to cooperate with tax authorities; filing false Forms W-
4; failure to make estimated tax payments; and engaging in
illegal activity. Bradford v. Commissioner, 796 F.2d 303, 307
(9th Cir. 1986), affg. T.C. Memo. 1984-601. The "badges of
fraud" are nonexclusive. Miller v. Commissioner, supra at 334.
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