What is the test for determining whether the evidence was insufficient to convict an individual of tax evasion?

"The relevant question [on whether the evidence was insufficient] is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." Jackson v. Virginia, 443 U.S. 307, 319 (1979).

To establish that tax evasion has occurred in violation of 26 U.S.C. 7201, the Government must prove the following elements: (1) the existence of a tax deficiency, (2) willfulness, and (3) an affirmative act constituting an evasion or an attempted evasion. Sansone v. United States, 380 U.S. 343, 351 (1965); United States v. Marabelles, 724 F.2d 1374, 1377 (9th Cir.1984).

a. The existence of a tax deficiency