United States Court of Appeals for the Fifth Circuit
558 F.2d 744 (1977)
The United States (plaintiff) charged Lewis Johnson (defendant) with filing false income tax returns for his corporations. At trial, Johnson sought to introduce evidence that he had overpaid on his personal income taxes by neglecting to take deductions for which he was eligible. The district court excluded this evidence as irrelevant. A jury convicted Johnson, and he appealed. Johnson argued that the evidence was relevant to demonstrate that he relied in good faith on his accountants in filing both his personal and corporate taxes. According to Johnson, his reliance on his accountants was evidence that he did not have any criminal intent.
Rule of Law
Holding and Reasoning (Simpson, J.)
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