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The court also found that Dee Wyly, the widow of Charles Wyly (who was Samuel Wyly’s brother and business partner), hadn’t committed tax fraud, even though she was a joint signer on Charles’ returns. However, she must pay taxes, penalties and interest for a gift to her children. In addition, the court addressed the Wylys’ failure to file certain forms reporting the offshore accounts and gift tax issues.

Source: Lessons Learned From U.S. Tax Fraud Case