Criminal Tax Evasion and Taxpayer Intent
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.
Finance and General Business
Leasure, Stanley A., and Debra H. Oden. "Criminal Tax Evasion and Taxpayer Intent." The CPA Journal 79, no. 6 (2009): 38-44.