[tshaddox]

It is, under any remotely common usage of the term. A victimless crime is one where the directly involved parties all consented to the action.

If you consider the government itself as a "directly-involved party" then you would consider no crime to be victimless, since it's always the government who prosecutes a crime.

If you invoke something like "society at large" as the victim, then again you can exclude any action from being a victimless crime if you happen to think society is worse off if that action happens (e.g. certain sexual acts between consenting adults, certain types of drug use, etc.).

Tax evasion, along with similar crimes like smuggling and insider trading, are widely listed as examples of victimless crimes.