Identify Which of the Following Statements Is False

Identify which of the following statements is false.

A) The fraud penalty can be imposed with respect to income, gift, and estate tax returns.
B) If fraud is asserted in a tax transaction, the burden of proof falls on the IRS.
C) The government must prove its case "beyond a reasonable doubt" in order for the court or jury to convict a taxpayer of criminal fraud.
D) The civil fraud penalty consists of 75% of the tax underpayment attributable to fraud plus 25% of the interest payable on the portion of the underpayment resulting from the fraud.