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Definition of "Willful" in Civil Cases Includes Reckless Disregard of Tax Laws

Definition of "Willful" in Civil Cases Includes Reckless Disregard of Tax Laws

District Court finds in FBAR penalty trial that the definition of willful in civil cases includes reckless disregard of tax laws. The Court found that the burden of proof in a civil FBAR penalty case was a mere preponderance of the evidence. The IRS was not bound by the opinion of General Counsel or its own manual that state that the definition of willful should be the same in civil cases as in criminal cases.

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Evidence of Tax Fraud Conspriacy was Sufficent to Deny Rule 29 Motion U.S. v. MUYABA and MUDEKUNYE, LEXIS 14169 (5TH Cir. 2011)

Defendants were convicted of tax fraud conspiracy charges. The defendant's asserted that their rule 29 motion alleging insufficient evidence, should have been granted.

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