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Christmas in May: Tax Court Judge Lynn W. Davis' Extraordinary Decision ( October 2003 )
Usually with indignant disbelief, my taxpayer clients often lecture me that constitutional safeguards routinely extended to others, like accused felons and “garden variety” plaintiffs, find no counterparts in the tax world. The taxpayers’ point is that the state must prove criminal guilt “beyond a reasonable doubt,” while the reverse applies to taxpayers, who must prove the taxing authorities’ presumptively correct assessments are wrong.
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