U.S. v. Clarke

Record contained sufficient evidence to support jury’s guilty verdict on seven counts of presenting false claims under 18 USC section 287 arising out of defendant’s submission of multiple income tax returns for 2006, 2007 and 2008. While defendant argued that record failed to contain any evidence that he willfully presented false claims in said tax returns, govt. need not prove willfulness under section 237, but only that defendant knew said claims to be false. As such, govt. made requisite showing where: (1) defendant listed in each return $900,000 in income without identifying how said income was obtained, as well as contended that $300,000 of said income was withheld, without providing any proof of such withholding; and (2) defendant’s submission of patently false and utterly groundless claims in his returns was sufficient to establish his knowledge of falsity of said claims.