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U.S. v. Silkman, No. 99-4338 (8th Cir.) (220 F.3d 935) (August 30, 2000) (Judge James B. Loken)

Here, after the defendant was convicted of tax evaision following an earlier remand, the Court held that an unchallenged certificate of assessment is prima facie evidence of a deficiency when a taxpayer who filed no return is charges with tax evasion.

Here the Court concluded: "When a taxpayer fails to ...

 

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