Federal Tax Crimes blog says The Big Lie is at the heart of the Daugerdas tax shelter indictment:
I have blogged before that tax shelter prosecutions are about the lie. Often, the claim is that the tax shelters lack economic substance, but in these prosecutions the real complaint is the lie that is designed to give an appearance of economic substance. The jury will not understand the complex, convoluted tax structure and byzantine legal analysis, but the jury will understand the lie.
Federal Tax Crimes Blog is all over this case.