An Extension We Don't Want-Tax Preparer's Fraud Taints Return for Statute of Limitation

When Section 6501(c) refers to a false and fraudulent return, does the IRS need to show that the taxpayer was involved in the fraud to get the benefit of the unlimited statute of limitations to assess tax?  Or is it enough to show only that the preparer was involved in preparing a false return with the intent to evade tax on behalf of the taxpayer?  That's the issue the Tax Court considered in the case of Allen v. Commissioner, 128 TC No. 4.The supporting materials for this podcast can be downloaded from http://edzollars.com/2007-03-10_Preparer_Fraud.pdf .The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com .