"Some have suggested that the Commissioner of Internal Revenue...rarely loses in tax court, tax court decisions are rarely appealed, and federal circuit courts rarely reverse tax court decisions," Judge Richard Wesley wrote for the court. "Despite some of these expectations, after losing in tax court, the Commissioner appealed, and we now reverse."
Ignorance of Fraud Found No Shield Against Tax Evasion Liability
New York Law Journal
March 8, 2013
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