The third set of appeal grounds also relate - according to the documents - to undisclosed information for which the UK Government had sought public interest immunity from disclosure.

BBC: Law chief 'deplores' bomber claim

The IRS has embarked on an aggressive campaign to track down the identities of individuals with undisclosed foreign accounts by relying on information that is increasingly available to them under tax treaties, through submissions by whistleblowers, and the Foreign Account Tax Compliance Act (FATCA).

FORBES: IRS OVDI Offers Penalty Relief for Dual Citizens

In the cases prosecutors are able to win, the accused are most often company outsiders who come across undisclosed material information and use it to their advantage.

FORBES: A Glimmer Of Hope

The information and advice they have been providing regarding asset allocation, manager selection and performance has been tainted by undisclosed conflicts of interest, hidden financial arrangements and outright fraud.

FORBES: Murders and Pensions: The Need for Forensic Investigations (March 28, 2006 )