POSNER, Circuit Judge.
After two failed efforts to prosecute William and Barbara Spitz for criminal tax evasion, the government assessed civil fraud penalties against them. 26 U.S.C. § 6653(b)(1). They challenged the assessment in the Tax Court, which while throwing out much of the government's case upheld the assessment of fraud penalties totaling $1,843 for 1977 and 1978. The Spitzes appeal. The government concedes that its burden was to prove fraud by clear...
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