Filippo Candela and Providenza Candela v. United States

WILLIAM J. CAMPBELL, Senior District Judge.

This appeal presents two issues: whether the taxpayers successfully overcame the Commissioner of Internal Revenue’s determination of a tax deficiency; and whether the Commissioner established, by clear and convincing evidence, that these deficiencies were the result of fraud. The plaintiffs-taxpayers have the burden of proof on the first issue, the Commissioner on the latter. The District Court, after a bench trial, concluded that the taxpayers had failed to rebut the deficiency determinations, and that the deficiencies were the product of fraud.…