The Financial Inability Defense to Tax Crimes
Steve R. Johnson
Florida State University - College of Law
ABA Section of Taxation News Quarterly, Vol. 23, No. 3, p. 6, Forthcoming
FSU College of Law, Public Law Research Paper
Your client files an income tax return correctly stating her tax liability, but she does not pay the reported liability. Usually, this is a civil matter, implicating the failure-to-pay penalty of section 665l(a)(2). In aggravated circumstances, it can become criminal under either section 7201 or section 7203.
Number of Pages in PDF File: 2Accepted Paper Series
Date posted: September 29, 2011
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