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As a result, the relator’s burden to prove the tax obligation required proof that the taxpayer had a tax collection and remittance obligation (or nexus) under Illinois tax law that would not offend U.S. commerce clause nexus principles.9 While proving attributional nexus is an arduous factual task, the additional requirement to prove that the taxpayer acted with a “knowing” mental intent significantly increases the relator’s difficulty in proving a FCA violation. [read post]