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Knowingly, Willfully and Materiality

In United States v. Phillips , ___ F.3d ___, 2013 U.S. App. LEXIS 18430 (7th Cir. 2013) (en banc), here , the Seventh Circuit reversed convictions under "18 U.S.C. § 1014 [ enhanced version available to lexis.com subscribers ], which criminalizes 'knowingly mak[ing] any false statement...

Good Opinion on Error in Not Giving Requested Good Faith Belief Instructions

Tax practitioners and students cannot be reminded too often on the importance of Cheek 's definition of willfulness - voluntary intentional violation of a known legal duty -- and Cheek 's holding that a sincerely held even if objectively unreasonable belief that the conduct is lawful requires...