Therefore, we review a district court’s factual findings to determine if they "support the ultimate legal conclusions reached." Zack v. Comm’r , 291 F.3d 407, 412 (6th Cir. 2002). However, "[w]e do not insist that trial courts make factual findings directly addressing each issue that a litigant raises."

Grover Hill Grain Co. v. Baughman-Oster, Inc., 728 F.2d 784, 793 (6th Cir. 1984) (citing Huard-Steinheiser, Inc. v. Henry, 280 F.2d 79 (6th Cir. 1960)). Accord Zack v. Commissioner of Internal Revenue, 291 F.3d 407, 412 (6th Cir. 2002).

Id. "Implicit in this finding," the court explained, "is that [the sanctioned party] improperly used the court system to try to force a result that it could not obtain under the applicable law, which is separate and district [ sic] from the issue of whether [the sanctioned party] was attempting to prevail on the merits of its lawsuit and collect payment on a meritless claim." Id.; see also id. at 525 n. 19 ("Our inference is in accord with this Court's ruling . . . that `[i]f, from the facts found, other facts may be inferred which will support the judgment, such inferences shall be deem [sic] to have been drawn by the District Court.'") (quoting Zack v. Comm'r of Internal Revenue, 291 F.3d 407, 412 (6th Cir. 2002)). The dissent, however, challenged the suggestion that it is possible to infer "that a claim is filed for an `improper purpose' if the claim is `invalid' and is put forth by a litigant who knows that the claim is invalid."

As a general rule "[w]e review the tax court's legal conclusions de novo and its factual findings under the `clearly erroneous' standard." Zack v. Comm'r, 291 F.3d 407, 412 (6th Cir. 2002); Indmar Prods. Co. v. Comm'r, 444 F.3d 771, 777 (6th Cir. 2006) ("We review the Tax Court's factual findings for `clear error' and its application of law de novo."); MTS Int'l Inc. v. Comm'r, 169 F.3d 1018, 1021 (6th Cir. 1999) ("This court reviews the tax court's legal conclusions de novo and its findings of fact under the `clearly erroneous' standard."). In turn, "[f]actual findings are clearly erroneous if, based upon the entire record, the reviewing court is `left with the definite and firm conviction that a mistake has been committed.'"

In evaluating the district court's guilty verdict, we first assess whether its findings "support the ultimate legal conclusions" of Guy's guilt under 18 U.S.C. § 1344 and 18 U.S.C. § 1708. Id. at 852 (quoting Zack v. Comm'r, 291 F.3d 407, 412 (6th Cir. 2002)). Then, we will uphold a district court's ultimate finding of guilt if, "after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt."

It applies when "a single transaction or taxable event ha[s] been subjected to two taxes on inconsistent legal theories." Zack v. Comm'r, 291 F.3d 407, 414 (6th Cir. 2002) (quoting Rothensies v. Elec. Storage Battery Co., 329 U.S. 296, 300 (1946)). That such an occurrence is exceedingly rare is clear from the paucity of case law in this court applying the doctrine, and the fact that most such cases end in failure for the party seeking to invoke its protection.

It applies when "a single transaction or taxable event ha[s] been subjected to two taxes on inconsistent legal theories." Zack v. Comm'r, 291 F.3d 407, 414 (6th Cir. 2002) (quoting Rothensies v. Elec. Storage Battery Co., 329 U.S. 296, 300 (1946)). That such an occurrence is exceedingly rare is clear from the paucity of case law in this court applying the doctrine, and the fact that most such cases end in failure for the party seeking to invoke its protection.

So, to the extent the jury was advisory here—and, though not entirely clear from the record, it appears that it was—the rule requires findings of fact and conclusions of law. Id.; see Zack v. Comm'r, 291 F.3d 407, 412 (6th Cir.2002) (“[T]he trial court's findings [under Rule 52(a) ] must support the ultimate legal conclusions reached. The findings are necessary not only to reveal the logic behind the trial court's decision, but also to enable an appellate court to conduct a meaningful review of the trial court's order.”)

Findings are to be liberally construed in support of a judgment, even if those findings are not as detailed as we might desire. Zack v. C.I.R., 291 F.3d 407, 412 (6th Cir.2002) (affirming judgment); Grover Hill Grain Co. v. Baughman–Oster, Inc., 728 F.2d 784, 793 (6th Cir.1984) (reversing judgment where findings did not give clear understanding of basis for district court's decision); Travelers Ins. Co. v. Dunn, 228 F.2d 629, 631–32 (5th Cir.1956) (affirming judgment where district court stated oral finding that appellee had “testified truly”). Given the urgency of the matter the district judge had to decide, we should read his findings more charitably than my colleagues do so long as we can follow the path of his reasoning.

We review the Tax Court's legal conclusions de novo and its factual findings for clear error. Zack v. Comm'r, 291 F.3d 407, 412 (6th Cir. 2002); Ekman v. Comm'r, 184 F.3d 522, 524 (6th Cir. 1999). "A finding is clearly erroneous when, although there is evidence to support it, a review of the entire record leaves the reviewing court with the definite and firm conviction that a mistake has been made."