Whether, in a prosecution for aiding and assisting in the preparation or filing of false tax returns under 26 U.S.C. § 7206(2), the government is required to prove beyond a reasonable doubt that the accused voluntarily and intentionally violated a known legal duty as required by this Court's precedent; or whether, as the Eleventh Circuit held here, it is sufficient if the government merely proves a lower mens rea standard by proving that the accused simply acted with the intent to do something the law forbids?

QUESTION PRESENTED FOR REVIEW Mr. Manuel Antonio Severino was charged and convicted on thirteen counts of aiding and assisting in the preparation of false tax returns in violation of 26 U.S.C. § 7206(2) (Counts 1-18 of a 17-count indictment). That federal law makes it unlawful to willfully aid or assist in the preparation or filing of a federal income tax return “which is fraudulent or is false as to any material matter.” 26 U.S.C. § 7206(2). This Court’s precedent holds that “willfulness in [the § 7206] context simply means a voluntary, intentional violation of a known legal duty.” United States v. Pomponio, 429 U.S. 10, 12 (1976); United States v. Bishop, 412 U.S. 346, 460-61 (1973). This petition raises the following question: Whether, in a prosecution for aiding and assisting in the preparation or filing of false tax returns under 26 U.S.C. § 7206(2), the government is required to prove beyond a reasonable doubt that the accused voluntarily and intentionally violated a known legal duty as required by this Court’s precedent; or whether, as the Eleventh Circuit held here, it is sufficient if the government merely proves a lower mens rea standard by proving that the accused simply acted with the intent to do something the law forbids? i INTERESTED PARTIES There are no