Staszak v. United States Department of Justice

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that failure to file income tax returns and underestimating tax liability for purposes of estimated payments for the tax years at issue constituted evidence of willfulness
• test for materiality is whether particular item must be reported in order for taxpayer to assess tax liability correctly
• \Patterns of understating or failing to report income are . . . evidence of willfulness.\
• “[E]ventual cooperation with the government does not negate willfulness.”
• “[E]ventual cooperation with the government does not negate willfulness.”
• “Willfulness may be inferred from circumstantial evidence.”

Source: CourtListener parenthetical corpus (CC0).