Skatteforvaltningen v. Markowitz

Summary

The court affirmed judgments holding the defendants liable for defrauding Denmark’s tax authority through fabricated dividend-tax refund claims. It concluded that the common-law revenue rule did not apply because the defendants never owed or paid Danish taxes and the suit sought recovery of fraudulently disbursed funds, not collection of a foreign tax obligation. The court also upheld the evidentiary rulings and determined that sufficient evidence supported liability against the wives under an agency theory.