Time to Revisit the 'Klein' Conspiracy Doctrine

In his Tax Litigation Issues column, Jeremy H. Temkin, a principal in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, writes that federal tax indictments often include an allegation that the defendants conspired to "defraud the United States and the Internal Revenue Service by impeding, impairing, defeating and obstructing the lawful governmental functions of the IRS in the ascertainment, evaluation, assessment, and collection of income taxes."

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