u.s. v. whitt

. § 3631(a) in this case, under which the Government bears the burden of proving beyond a reasonable doubt that the defendant acted 'because of' race. ... Under the statute, the Government bears the burden of proving beyond a reasonable doubt that Whitt's racial animus was great enough to..

citigroup, inc. v. u.s.

It also argues that plaintiff bears the burden to prove the inclusionary component of the rule because plaintiff bears the burden in any tax refund suit to disprove the IRS's determination of tax liability. . 1. ... The taxpayer bears the burden of proving the IRS's determinations..

shih-fu peng v. u.s.

o escape the penalty, the taxpayer bears the heavy burden of proving both that the failure did not result from `willful neglect, and that the failure was `due to reasonable cause.. ..

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