The Internal Revenue Service believes that U. S. citizens have deposited money in Swiss banks in order to avoid taxation of the interest earned on those funds. Known as “offshore accounts,” their existence can save the wealthy millions in taxes. UBS AG initially refused to turn over any information about its customers. What steps could the IRS take to obtain the information? If, after obtaining the information, the U. S. Citizens claim that they were not sophisticated enough to know and understand the IRS rules, how would their statements affect actus reus of tax evasion?