Tax evasion in the United States unlawful gains as income when filing annual tax returns (see e.g., "James v. United States") although such income is typically not reported. Suspected lawbreakers, most famously Al Capone, have been successfully prosecuted for tax evasion when there was insufficient evidence to try them for their non-tax related crimes. Reporting illegal income as earned legitimately may be illegal money laundering. In the United States, the IRS estimate of the 2001 tax gap was $345 billion. For 2006, the tax gap is estimated to be $450 billion. A more recent study estimates the 2008 tax gap in the range of $450 to
UBS tax evasion controversies French court system, finally losing its appeal at the Cour de Cassation, France's highest court. UBS may appeal that ruling to the European Court of Human Rights. In February 2015, Bradley Birkenfeld, the key figure in the UBS tax evasion scandal in the U.S., was subpoeaned by French magistrate investigating the case. The U.S. Justice Department approved allowing Birkenfeld, who is still on parole, to visit France to testify against UBS. Federal Judge WIlliam Zloch gave Birkenfeld permission to travel to France from 27 February to 1 March 2015 to appear before the French court. In 2014, UBS accused the