In the context of civil tax fraud, the burden of proof is on the IRS to show by a "preponderance of the evidence" that the taxpayer had a specific intent to evade a tax.

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In civil tax fraud cases, the burden of proof is on the IRS to show that the taxpayer had a specific intent to evade a tax by a "preponderance of the evidence," which means it is more likely than not that the taxpayer committed the fraud. This is different from criminal tax fraud cases where the burden of proof is "beyond a reasonable doubt."

In the Context of Civil Tax Fraud, the Burden of Proof