D was an airplane pilot who believed that the federal income tax requirements were unconstitutional. He attended various seminars about this topic and sat in on various tax evasion trials.
D stopped paying income taxes.
D was indicted on willfully failing to file a tax return and willfully attempting to evade his income tax.
D honestly believed that he didn't have to pay income tax and represented himself at trial.
The jury was instructed that D was guilty if his belief was made in good faith but was unreasonable.
Procedural History:
District Court found D guilty.
COA affirmed, D guilty.
SCOTUS reversed, remanded for new trial.
Issues:
Does an honest but unreasonable belief negate a statute's requirement for willfulness?
Holding/Rule:
A claimed good-faith belief need not be reasonable in order to be considered as a defense.
Reasoning:
D was aware of his duty to file a return and to treat wages as income.
While the tax code is complex, the complexities are not reason for D to believe that the rules were unconstitutional.
Instead, this reveals that the D had full knowledge of the issues at hand and believed that the tax provisions were unenforceable.
The trial court's instruction about unreasonable beliefs was incorrect and grounds for reversal.
It was error to instruct the jury to disregard evidence of D's understanding that he was not a person required to pay income taxes, as crazy as this belief is.
The more unreasonable the belief, however, the more likely the jury will consider them to be nothing more than simple disagreement with known legal duties.
Dissent:
Blackmun: This will encourage people to hold crazy beliefs about tax laws just to get out of paying taxes.
