has not filed a federal income return is not necessarily indicative of whether he has paid income, FICA, or FUTA taxes. Nonetheless, based on Agent Brown’s review, the IRS concluded that several of the crew members’ 4669 Forms were not truthful and rejected the settlement offer. Following a two-day trial in May 1991 on the issue of Bill’s Forestry’s classification of crew members, the bankruptcy court issued an opinion disallowing the IRS’s claim. See In re Rasbury, 130 B.R. 990 (Bankr.N.D.Ala.1991). It held that in bankruptcy proceedings, unlike other proceedings, the IRS “has the ultimate burden of proving both the debtors’ liability to [the] IRS and the specific amount due.” Id. at 1001; compare Helvering v. Taylor, 293 U.S. 507, 515, 55 S.Ct. 287, 291, 79 L.Ed. 623 (1935) (<HOLDING>). The court found that the IRS had not proven
holding that even where taxpayer did not have the financial means to pay all of the taxes owed the taxpayer still willfully evaded tax obligation holding that a taxpayer cannot bring a suit for the return of illegally collected taxes if the payments were made voluntarily holding that the taxpayer has the burden to prove the governments tax assessment is incorrect holding in the context of a plaintiffs suit to recover income taxes that congress has preserved the immunity of the united states from declaratory  relief with respect to all tax controversies except those pertaining to the classification of organizations under  501c of the internal revenue code holding that in a proceeding to recover taxes from a nonbankrupt taxpayer the taxpayer has the burden of proving that his taxes complied with the internal revenue code