Questão jurídica principal
Whether the omission of the liquidation surplus constituted attempted direct federal tax evasion
Decisão extraída
The objective element was not decisive, but the taxpayer's intent to hide taxable income was not proven with sufficient certainty.
Fundamentação extraída
The liquidation surplus was taxable in 1996, and the return was incomplete; however, the unclear timing, the wording of the guidance, the role of the trustees, and the use of the withholding-tax notification left only negligence, not eventual intent.