The case appears to be related to Banister's one big court victory, his acquittal on charges of conspiracy and helping to prepare false tax returns in 2005. After his acquittal in 2005 the IRS dug into returns Banister was involved in with a view to assessing civil penalties. The amended return wipes out all the income and requests that all the income tax be refunded. This is important to non-resident aliens who have some income from the United States and some other special situations. The 861 regulations are probably not something you or I have to concern ourselves about so much.

Source: Forbes December 11, 2017 02:15 UTC