United States Fifth Circuit

The Tax Court clearly erred in finding that the government proved income taxpayers' deficiency due to fraud by clear and convincing evidence, but evidence supports assessment of the deficiency under a preponderance of evidence standard, thus deficiencies are affirmed for those years not barred by the statute of limitations.

Appellate Information

• Decided 07/30/2003
• Published 07/30/2003

Judges

Court

• United States Fifth Circuit

Counsel