Minnesota civil tax fraud

Interesting that Minnesota law, with respect to civil tax fraud, has traditionally put the burden of persuasion on the taxpayer to show a lack of fraud, in complete contrast to the federal rule.  F-D Oil Co., Inc. v. Commissioner, 560 N.W.2d 701 (Minn. 1997).  It is difficult to show in detail all the fraudulent activities that the taxpayer did not engage in.