Personal Income Tax Planning

This Podcast concerns the income tax statute of limitations.  When Code Section 6501(c) refers to a false and fraudulent return, does the IRS need to show that the taxpayer was involved in the fraud to be able to use the unlimited statute of limitations to assess tax?  Or is it enough to show only that the preparer was involved in preparing a false return with the intent to evade income tax on behalf of the taxpayer?  That's the issue the Tax Court considered in the case of Allen v. Commissioner, 128 TC No. 4.The supporting materials for this podcast can be downloaded from http://edzollars.com/2007-03-10_Preparer_Fraud.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com