U.S. v. Collins

Record contained sufficient evidence to support jury's guilty verdict on tax evasion charges stemming from defendant's failure to file income taxes for almost 20 years. Dist. Ct. properly rejected defendant's request for special jury instruction where instant pattern instruction properly defined willfulness, and where defendant could not attribute tax deficiency covering almost 20 years to mere negligence. Record also showed that defendant hid his income by commingling his personal and business accounts and using false Employer Identification number, as well as Social Security number of his deceased business partner.