| http://www.w3.org/ns/prov#value | - Compare Allen with City Wide v. Commissioner, where the Tax Court, looking at the statute of limitation extension attributable to willful attempts to defeat or evade under Section 6501(c)(2) (applicable to returns other than income or estate or gift tax returns), held that the IRS could not assess tax after the three-year statute expired, despite the preparer pleading guilty to the criminal offens
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