When is criminal liability considered complete?

• A. Upon final assessment
• B. Upon payment of tax
• C. Upon receiving a notice
• D. Upon willful act of evading taxes

Answer: (D)

Criminal liability in tax matters attaches when there is a willful act to evade or defeat the tax. The offense is considered complete at the moment that deliberate evasion is carried out with the required intent, such as filing false returns, concealing income, or engaging in fraudulent schemes. Civil processes like final assessment, payment of tax, or simply receiving a notice are administrative or civil steps and do not by themselves constitute a criminal act. The key idea is the combination of a willful intent to evade and the evasion act itself; once that is done, the crime is consummated.