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Univ. of San Diego School of Law

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Wednesday, October 19, 2011

Johnson on the Financial Inability Defense to Tax Crimes

Johnson, Steve R. - Florida State University CoLSteve R. Johnson (Florida State University - College of Law) has posted The Financial Inability Defense to Tax Crimes (ABA Section of Taxation News Quarterly, Vol. 23, No. 3, p. 6, Forthcoming) on SSRN. Here is the abstract:

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. 

http://lawprofessors.typepad.com/crimprof_blog/2011/10/xxx-johnson-on-the-financial-inability-defense-to-tax-crimes.html

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