If you read the court record (available on line through PACER) you will find that your analysis of the case is wrong. 

Your fundamental mistake is this:  Alan owned the company not his father at the time of the tax violations. 

You don't need to speculate on the nature of family dynamics or the hierarchical nature of business. Start and end with the facts. 

If you didn't like Jimmy stick to that. Don't justify an opinion with false "facts."