It revealed "numerous instances" where Ms. Fisher received compensation where there wasn't a legitimate business purpose.

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The corporate formalities were not followed and the LLC is a mere sham which serves no legitimate business purpose.

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It makes judges skeptical that the partnership was really set up for a legitimate business purpose, other than just saving taxes.

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Finally, the source of the unreported assets cannot be derived from illegal activity. (For this purpose, the proceeds of a tax evasion scheme from a legitimate business are not deemed to be from an illegal activity.) If all of these elements of voluntary disclosure are met, the IRS generally will not prosecute the taxpayer for the noncompliance.

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