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 ended its litigation with the IRS. U.S. Senator Carl Levin (D-MI), who conducted Senate hearings into the UBS tax evasion scandal, described the settlement agreement (known as the "Annex") "disappointing." [T]he tortured wording and the many limitations in this Annex shows the Swiss Government trying to preserve as much bank secrecy as it can for the future, while pushing to conceal the names of tens of thousands of suspected U.S. tax cheats. It is disappointing that the U.S. government went along. However, this settlement set up a showdown between the U.S. and Swiss governments over the secrecy of Swiss bank