The Conduct Too Remote Is Not Evasion Argument in the Larson & Pfaff Petition for Certiorari

I write to address, perhaps not in linear fashion, the second question presented in the Larson and Pfaff petition for certiorari (see prior blog here). That question is:

2. Whether for ten of the twelve counts of conviction petitioners’ conduct was too remote from the taxpayers’ returns to be charged under 26 U.S.C. §7201.

The charges in this case were (from the superseding indictment with the names of the dismissed and pleading defendants' names omitted):
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