The following excerpt is from U.S. v. Heun, 983 F.2d 1078 (9th Cir. 1992):
Assuming arguendo that the willfulness instruction included in the government's excerpt of record as jury instruction 15 was given to the jury, this did not result in plain error. Neither "bad purpose" nor "evil motive" is an element of willful failure to file an income tax return. See United States v. Powell, 955 F.2d 1206, 1211 (9th Cir.1992).
6. Nature and Cause of Accusations Against Heun
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