What is the current state of the law on the basis of "exceptional safeguards" used in the tax case?

evidence "would be completely conclusive on the merits." Id. In non-tax cases, however, the government typically cannot rely solely on such financial data; it therefore introduces a whole range of evidence, making the "exceptional safeguards" used in the tax context unnecessary. Id.; see also United States v. Hinton, 543 F.2d 1002, 1013 (2d Cir. 1976) ("Appellants were free to rebut this evidence with proof that they had sufficient prior net worth to fund the expenditures they had made....").