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Tax Lawyer, Vol. 63, No. 2 NOTE 621621NOTETax Evasion—To Convict or Collect? Can the Government Have It Both Ways Under the Expanded Definition of “With Respect to Stock” in Section 301 After Boulware v. United States?I. IntroductionIn seeking to impose civil and criminal sanctions on a taxpayer who improperrl diverted corporate funds without reporting any income, the government’s arguments in Boulware v. United States1 forced the government between a “rock and a hard place.”2 At oral argument...