The Financial Inability Defense to Tax Crimes
ABA Section of Taxation News Quarterly, Vol. 23, No. 3, p. 6, Forthcoming
2 Pages Posted: 29 Sep 2011
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.
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