U.S. v. Beavers

In prosecution on tax fraud charges stemming from defendant’s failure to report as income his receipt of money from various campaign funds, Dist. Ct. did not err in excluding evidence that defendant had amended his tax returns and made payments to reimburse his campaign committees that occurred after federal agents approached defendant during their investigation of his activities. While defendant argued that said evidence was probative of his good faith and lack of intent to file fraudulent tax returns, Dist. Ct. could properly condition said admission on defendant’s ability to show that said actions had connection to his state of mind at time he filed his incorrect returns, which defendant did not do since he failed to testify and otherwise presented defense that said transfers were loans and not income. Moreover, Dist. Ct. did not impermissively infringe on defendant’s 5th Amendment rights by forcing him to either testify or forego opportunity to present instant state of mind evidence since defendant does not have unfettered right to present testimony that is not admissible under standard rules of evidence.