United States Supreme Court
498 U.S. 192 (1991)
John Cheek (defendant) was involved with an anti-tax advocacy group that claimed that federal tax laws were unconstitutional. Based on the group’s advice, Cheek stopped filing federal tax returns. Cheek was charged with several counts willfully failing to file a federal income tax return for a number of years in violation of 26 U.S.C. § 7201 and 26 U.S.C. § 7203(1), which are specific intent crimes. At trial, Cheek’s defense rested on his sincerely held belief that he owed no taxes on his wages. The trial judge instructed the jury that an “honest but unreasonable belief is not a defense and does not negate willfulness.” The jury was also instructed that a “persistent refusal to acknowledge the law does not constitute a good faith misunderstanding of the law.” Cheek was convicted, and he appealed. The court of appeals affirmed his conviction, and the United States Supreme Court granted certiorari to review.
Rule of Law
Holding and Reasoning (White, J.)
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