stating that while a good faith belief does not have to be reasonable, “the more unreasonable the asserted beliefs or misunderstandings are, the more likely the jury will consider them to be nothing more than simple disagreement with known legal duties imposed by the tax laws and will find that the Government has carried its burden of proving knowledge”
How later courts described this case
- stating that while a good faith belief does not have to be reasonable, “the more unreasonable the asserted beliefs or misunderstandings are, the more likely the jury will consider them to be nothing more than simple disagreement with known legal duties imposed by the tax laws and will find that the Government has carried its burden of proving knowledge”
- holding that to carry its burden of the knowledge component of the willfulness requirement, the government was required to “negative] a defendant’s claim of ignorance of the law or a claim that because of a misunderstanding of the law, he had a good-faith belief that he was not violating any of the provisions of the tax laws.”
- recognizing the “duty to file a return and to treat wages as income ” and holding that a good faith misconception is a defense to federal criminal charges of willfully failing to file a federal income tax return and willfully attempting to evade income taxes
- stating that carrying the government’s burden “requires negating a defendant’s claim of ignorance of the law or a claim that because of a misunderstanding of the law, he had a good-faith belief that he was not violating any of the provisions of the tax laws”
Written by the judges who cited it.
Distinguished
Distinguished by United States v. Bursey, 416 F.3d 301 (2005)
As in Bryan, the Ratzlaf and Cheek line of decisions are inapposite to these circumstances, where the Statute is not technical like the currency and taxation laws and the danger of an innocent state of mind is diminished.
Distinguished by United States v. Gilberg, 75 F.3d 15 (1996)
498 U.S. 192, 111 S.Ct. 604, 112 L.Ed.2d 617 (1991), are inapposite.
The opinion
Justice Blackmun,
with whom Justice Marshall joins, dissenting.
It seems to me that we are concerned in this case not with “the complexity of the tax laws,” ante, at 200, but with the income tax law in its most elementary and basic aspect: Is a wage earner a taxpayer and are wages income?
The Court acknowledges that the conclusively established standard for willfulness under the applicable statutes is the “‘voluntary, intentional violation of a known legal duty.’” Ante, at 201. See United States v. Bishop, 412 U. S. 346, 360 (1973), and United States v. Pomponio, 429 U. S. 10, 12 (1976). That being so, it is incomprehensible to me how, in this day, more than 70 years after the institution of our *210 present federal income tax system with the passage of the Income Tax Act of 1913, 38 Stat. 166 , any taxpayer of competent mentality can assert as his defense to charges of statutory willfulness the proposition that the wage he receives for his labor is not income, irrespective of a cult that says otherwise and advises the gullible to resist income tax collections. One might note in passing that this particular taxpayer, after all, was a licensed pilot for one of our major commercial airlines; he presumably was a person of at least minimum intellectual competence.
The District Court’s instruction that an objectively reasonable and good-faith misunderstanding of the law negates willfulness lends further, rather than less, protection to this defendant, for it adds an additional hurdle for the prosecution to overcome. Petitioner should be grateful for this further protection, rather than be opposed to it.
This Court’s opinion today, I fear, will encourage taxpayers to cling to frivolous views of the law in the hope of convincing a jury of their sincerity. If that ensues, I suspect we have gone beyond the limits of common sense.
While I may not agree with every word the Court of Appeals has enunciated in its opinion, I would affirm its judgment in this case. I therefore dissent.