The article presents information on the criminal tax cases and the claims of ignorance of relevant legal duties or misunderstanding. The complexities in the tax code of the U.S., interpretation of willful blindness by the U.S. courts and the standard for conviction are discussed. The non-tax fraud case law, strict interpretation of conscious avoidance in tax statutes and the duty implicitly imposed on taxpayers are also discussed with reference to the trial of Cheek v. United States.
Sniping down Ignorance Claims: The Third Circuit in United States v. Stadtmauer Upholds Willful Blindness Instructions in Criminal Tax Cases,
Vill. L. Rev.
Available at: https://digitalcommons.law.villanova.edu/vlr/vol56/iss4/5