Identify Which of the Following Statements Is False

Identify which of the following statements is false.

A) If fraud is asserted in a tax transaction, the burden of proof falls on the IRS.
B) The civil fraud penalty consists of 75% of the tax underpayment attributable to fraud plus 25% of the interest payable on the portion of the underpayment resulting from the fraud.
C) The government must prove its case "beyond a reasonable doubt" in order for the court or jury to convict a taxpayer of criminal fraud.
D) The fraud penalty can be imposed with respect to income, gift, and estate tax returns.

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