"Criminal Tax Evasion and Taxpayer Intent" by Stanley A. Leasure and Debra H. Oden
 

Title

Criminal Tax Evasion and Taxpayer Intent

Abstract

The article focuses on the ruling of the U.S. Supreme Court in Boulware versus U.S. that a conviction for tax evasion needs proof of a tax deficiency. It was further held that the characterization of corporate distributions as nontaxable returns of capital or taxable dividends should be made in a mechanical fashion. It is said that the ruling resolved a long-standing split between the Circuit Courts of Appeal with regard to the application of the return-of-capital defense in criminal tax cases.

Department(s)

Finance and General Business

Document Type

Article

Publication Date

5-1-2006

Journal Title

CPA Journal

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