KPMG Partners Indicted with Conspiracy to Defraud the Government

The US Department of Justice has indicted eight former partners of KPMG of conspiracy to defraud the federal government. The DOJ alleges that the partners helped wealthy customers "evade billions of dollars in taxes" from 1996 through 2002 through creative tax shelters. A key factor in the partners' defense is that the tax shelters in question have never been declared illegal by the US courts. Do you think the KPMG partners are guilty?
Resources:

• 8 Former Partners of KPMG Are Indicted (New York Times, free registration required),
• Remarks of Attorney General Alberto R. Gonzales Regarding the KPMG Corporate Fraud Case (Dept of Justice),
• KPMG to Pay $456 Million for Criminal Violations (IRS),
• Statement by IRS Commissioner Mark W. Everson (IRS),
• KPMG Statement Regarding Settlement in Department of Justice Investigation (KPMG press release),
• KPMG Settlement Documents (compiled by the Tax Professor's Blog).

For more information:

• Tax Shelters - learn about the difference between illegal tax schemes and legal tax shelters,
• Tax Planning Tips - find legal tax tips and strategies,
• How to Pay Zero Taxes - the only book analyzing every tax shelter ever created, and tells you what's legal and what's illegal.
• Indictment (Definition) - from the About Guide to Crime