N.C.P.I.—Crim. 259.53

The defendant has been charged with willfully1 [aiding] [assisting]

[procuring] [counseling] [advising] the [preparation] [presentation] [filing]

of a [fraudulent] [false] tax document.

For you to find the defendant guilty of this offense the State must

prove four things beyond a reasonable doubt:

First, that the defendant pursuant to or in connection with the revenue

laws willfully [aided] [assisted in] [procured] [counseled] [advised] the

[preparation] [presentation] [filing] of a(n) [return] [affidavit] [claim]

[(describe other document)];

Second, that the defendant knew this document was [fraudulent]

[false] as to any material matter, whether or not the [falsity] [fraud] was

with the [knowledge] [consent] of the person [authorized] [required] to

[present] [[file the [return] [affidavit] [claim] [(describe other document)]];

Third, that the defendant was an income tax return preparer2;

And Fourth, that the amount of all taxes evaded on returns filed in the

taxable year (describe taxable year, e.g. 2015) was [one hundred thousand

dollars ($100,000) or more] [less than one hundred thousand dollars

($100,000)]3.

If you find from the evidence beyond a reasonable doubt that on or

about the alleged date the defendant pursuant to or in connection with the

revenue laws willfully [aided] [assisted in] [procured] [counseled] [advised]

the [preparation] [presentation] [filing] of a(n) [return] [affidavit] [claim]

[(describe other document)], that the defendant knew this document was

[fraudulent] [false] as to any material matter, whether or not the [falsity]

[fraud] was with the [knowledge] [consent] of the person [authorized]

[required] to [present] [[file the [return] [affidavit] [claim] [(describe other

document)]], that the defendant was an income tax return preparer, and

that the amount of all taxes evaded on returns filed in the taxable year

(describe taxable year) was [one hundred thousand dollars ($100,000) or

more] [less than one hundred thousand dollars ($100,000)], it would be

your duty to return a verdict of guilty. If you do not so find or have a

reasonable doubt as to one or more of these things, then it would be your

duty to return a verdict of not guilty.4