Reprinted with permission from The Tax Lawyer, February 2016

For more than a century, U.S. tax evaders have been liable for unpaid tax at any time so that statutes of limitation do not stymie collection of fruits of fraud. Today, however, federal courts of appeal are split over a novel doctrine that holds unwitting victims of abusive tax professionals strictly and perpetually liable for their mistake. Read More

Copyright © 2016 by Ballard Spahr LLP.
(No claim to original U.S. government material.)

All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.

Related Practices