Pages

▼
Showing posts with label Burden of Proof - Civil Fraud. Show all posts
Showing posts with label Burden of Proof - Civil Fraud. Show all posts
Sunday, July 12, 2026

FTPB Working Draft 2026 Revisions on § 6501(c) Unlimited Civil Statute of Limitation for Fraud (7/12/26)

›
In working on my working draft for the Federal Tax Procedure 2026 editions (due for publication on SSRN in early August), I have substantial...
Saturday, May 30, 2026

Tax Court Holds that IRS Must Prove Return Fraud After a Convicted Spouse is Convicted for Tax Evasion (5/30/26)

›
In Li v. Commissioner , T.C. Memo. 2026-42 (T.C. Case 12133-23 at #35, here , at #35, and GS here , the C ourt addressed proof issues for ap...
Monday, March 4, 2013

Second Circuit Holds That Fraud on the Return -- Even If Not the Taxpayer's -- Causes an Unlimited Civil Assessment Statute of Limitations to Apply (2/4/13)

›
THIS BLOG ENTRY IS A CUT AND PASTE FROM AN ENTRY WITH THE SAME TITLE ON MY FEDERAL TAX CRIMES BLOG, HERE . I have written in the past on ...
Saturday, October 20, 2012

Relationship Between Tax Court and Refund Fora - Burden to Prove Fraud (10/20/12)

›
In my Federal Tax Procedure course (and I presume similar courses taught by others), we cover the principal fora to litigate tax disputes.  ...
Sunday, September 9, 2012

Case on Collateral Estoppel [Issue Preclusion] as to Civil Fraud (9/9/12)

›
I have just posted on my Federal Tax Crimes Blog a short discussion of the recent case of Anderson v. Commissioner , 2012 U.S. App. LEXIS 18...
Thursday, August 2, 2012

Civil Tax Fraud - IRS Burden of Proof and Negative Inference from Fifth Amendment Silence (8/2/12)

›
In the Tax Procedure class, we study fraud with respect to tax obligations.  Fraud has criminal and civil components.  Although we cover bri...