In Loren-Maltese v. Commissioner, T.C. Memo. 2012-214 , the Tax Court introduces the legal issues as follows:
It's the facts that make this case interesting, but there are three issues of law that color its background: the general rules of tax...
Readers interested in the risks of being audited with respect to income tax noncompliance arising from foreign assets (particularly financial accounts) often ask what it takes for the IRS to prove fraud. I am aware of no standard litmus test of civil...