Month: December 2019
Is Mental Incapacity a Defense to “Willful Behavior” Penalties?
By of MillarLaw A Professional Corporation On Sunday, December 1, 2019
By: Sanford I. Millar © The Tax Crimes Handbook of the Office of Chief Counsel, Criminal Tax Division of the Internal Revenue Service defines “Willfulness ” as follows: “[a] Willfulness is defined as the “voluntary, intentional violation of a known legal duty.” Cheek v. United States, 498 U.S. 192, 200-01 (1991); United States v. Pomponio, … Continue reading Is Mental Incapacity a Defense to “Willful Behavior” Penalties?
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