What is the test for establishing intent to distribute a large quantity of drugs?

Of course, when facts are well-known, notice can be taken by juries (and judges), and the Government, like any other party, need not demonstrate that which is obvious. The Government does not have to present expert testimony showing that the possession of 100 kilograms of cocaine is more consistent with selling than using. See, e.g., United States v. Brown, 921 F.2d 785, 792 (8th Cir.1990) (noting that a jury can reasonably infer an intent to distribute "solely from possession of a large quantity of drugs"). But on close and contested factual issues, the Government must always prove its points through evidence presented at trial.

The reason for requiring such a valid evidentiary basis for crucial conclusions is quite

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