Michael Boulware v. Commissioner of IRS

Opinion for the Court filed by Senior Circuit Judge GINSBURG.

GÍNSBURG, Senior Circuit Judge:

In 1993 the Internal Revenue Service began a criminal investigation into Michael Boulware’s financial dealings, which ultimately led to his convictions for tax evasion and tax fraud. See United States v. Boulware, 558 F.3d 971 (9th Cir.2009). Boulware is the president and sole owner of two companies, Hawaiian Isle Enterprises, Inc. and HIE Holdings, Inc., which paid his legal and professional fees in the criminal trial and. other litigation from 1998-2002. Because Boulware did not report the payménts,…