Facts of the Case
Defendant was convicted of murder. On appeal, he asserted that the government failed to prove beyond a reasonable doubt the corpus delicti of murder and that, even if evidence of prior acts was admissible to prove the corpus delicti, the evidence in this case was inadmissible because it was too insubstantial. Defendant also contended that even if the evidence of prior acts was otherwise admissible, the jury was improperly instructed by the district court with regard to the consideration it might give to such evidence.
Did the district court have jurisdiction to consider the applicability of the valuation misstatement penalty under the Internal Revenue Service Code?(1) Does the penalty for overstatement apply to situations in which the tax underpayment resulted from a transaction that was determined to lack economic substance?