In a bankruptcy fraud case the government sought to introduce evidence of a prior conviction for willful failure to pay child support. The Defendant objected. The Government argued that it was a specific intent crime equivalent to willful failure to pay tax under section 7203. The Court disagreed.
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There is No Requirement That The Government Prove a Taxpayer Had Funds to Pay Tax to Obtain a Conviction Pursuant to Section 7202. Further, the Statute of Limitations for an Offense Under Section7202 is Six Years.