LexisNexis® Legal Newsroom
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...

Court of Appeals Rejects Arguments that Instructions on Willfulness and Good Faith Were Reversible Error

In United States v. Basile , 2014 U.S. App. 12388 (3d Cir. 2014), here , the defendants, husband and wife, chiropractors, engaged an asset protection firm who put them into offshore entities and bank accounts to avoid tax. The defendants took other actions to obscure their income and avoid tax. The defendants...