US-CA9 · jury_instructions
9th Cir. Model Jury Instr. (Criminal) 22.6
Willfully—Defined (26 U.S.C. §§ 7201, 7203, 7206, 7207)
To prove that the defendant acted “willfully,” the government must prove beyond a reasonable doubt that the defendant knew federal tax law imposed a duty on [him] [her], and the defendant intentionally and voluntarily violated that duty.
[If the defendant acted on a good faith misunderstanding as to the requirements of the law, [he] [she] did not act willfully even if [his] [her] understanding of the law was wrong or unreasonable. Nevertheless, merely disagreeing with the law does not constitute a good faith misunderstanding of the law because all persons have a duty to obey the law whether or not they agree with it. Thus, to prove that the defendant acted willfully, the government must prove beyond a reasonable doubt that the defendant did not have a good faith belief that [he] [she] was complying with the law.]
Provenance
- Source
- ce9.uscourts.gov
- Retrieved
- 2026-08-20
- Edition
- 2026-08-20
- Content hash
c52b8d71a0c99b980a00e25f4234fe5e750ae4f143a811024ac5ab8aef3c6ea7
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