Larson v. United States

(1) Whether the court of appeals correctly held that any ambiguity in the application of the "economic substance" doctrine did not negate the jury’s finding that petitioners acted willfully in committing tax evasion; and (2) whether the court of appeals correctly held that 26 U.S.C. § 7201, which provides that "[a]ny person who willfully attempts in any manner to evade or defeat any tax . . . [is] guilty of a felony," may be applied to petitioners because they assisted third-party taxpayers in filing false tax returns.