F.3d at 1159 (taxpayer bears burden of “clearly showing” right to claimed deduction); see also 26 U.S.C. § 274(d) (deductions for “any traveling expense” and “for any item with respect to an activity which is of a type generally considered to constitute entertainment, amusement, or recreation” requires substantiation of: (1) the amount of such expense; (2) the time and place of the travel, entertainment, amusement, or recreation; (3) the business purpose of the expense; and (4) the business relationship to the taxpayer of the persons entertained). The Tax Court did not clearly err in imposing a civil fraud penalty under 26 U.S.C. § 6663(a) because Edward Daoud’s underpayment of his tax liability in 2000 was attributable to fraud. See Bradford v. Comm’r, 796 F.2d 303, 307 (9th Cir.1986) (<HOLDING>). The Tax Court did not clearly err in imposing
holding that an agreement may be inferred entirely from circumstantial evidence holding that employers intent may be inferred through circumstantial evidence holding that proof of some or even all of the badges may not show intent holding that fraud may be inferred from circumstantial evidence holding that fraud may be inferred from circumstantial evidence including such badges of fraud as understatement of income inadequate records and implausible or inconsistent explanations of behavior