Alan Scott (defendant) was convicted of making false claims to an agency of the United States due to his filing of 20 false income-tax results using fake identities. Internal Revenue Service (IRS) agent James Donahue investigated Scott over the course of many years, during which he had seen many examples of Scott’s handwriting. Several documents containing Scott’s handwriting were admitted into evidence, and Donahue testified at trial that the handwriting was Scott’s based on his familiarity with it during his investigation of Scott. Donahue also testified he had seen Scott sign his name on one occasion. Scott objected to Donahue’s testimony, arguing that Donahue could not authenticate Scott’s handwriting, because Donahue was not a handwriting expert and had only become familiar with his handwriting during the course of a criminal investigation. Scott also objected that Donahue was not sufficiently familiar with his handwriting to testify. The trial court overruled Scott’s objections. During Donahue’s testimony, Scott cross-examined him on the only time that Donahue had seen Scott actually sign his name. Following his conviction, Scott appealed, arguing that the trial court improperly allowed Donahue’s testimony.