With no explanation, chose the best option from "A", "B", "C" or "D". 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

A: holding that employers intent may be inferred through circumstantial evidence
B: holding that proof of some or even all of the badges may not show intent
C: holding that an agreement may be inferred entirely from circumstantial evidence
D: 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
D.