---See: United States v. James R. Back, No. 14-30265, United States Court of Appeals for the Ninth Circuit (July 2, 2018) (emphasis added) (not for publication), at:[James] Back's trial strategy depended on convincing the jury that, at all relevant times, he had a subjective "good faith" belief that his actions were legal, so as to preclude a finding of willfulness. But the government's evidence of willfulness— though circumstantial—was overwhelming. The government's evidence showed that everyone from Back's employer, to his boss, to a tax court, to the IRS, told Back that his position was frivolous. Moreover, Back sent his employer a phony "Certification of Federally Privileged Status" he doctored to look like an IRS document, which suggests an intent to deceive. Even after he was warned that he faced penalties for his false returns, he declined to amend them and then stopped filing returns altogether. Back did not offer any affirmative evidence of "good faith." Nor does Back challenge the sufficiency of the government's evidence on appeal.
https://scholar.google.ca/scholar_case? ... s_yhi=2018