Whether the IRS can require trustees to report year-end trust balances on personal income tax returns in violation of Napue v. Illinois and the Internal Revenue Code

1. Whether the lower courts violated, Napue v. Illinois, 360 U.S. 264, 269 (1959), thus effectuating a constitutional violation below and establishing a new precedent permitting the IRS to require trustees to report on the schedule C of their personal income tax returns, the year-end balances held in trust — funds that are legally owed to third parties; thus, resulting in the imposition of an additional tax not authorized by, nor contemplated under, the Internal Revenue Code. 2. Does a split among the circuits call for a review of this Honorable Court, more specifically was the Petitioner ’s right to a fair trial violated when the prosecution introduced evidence of a prior professional discipline under Federal Rule of Evidence 404(b), despite the lack of a clear nexus to the charged conduct, thereby inviting the jury to convict based on impermissible character inferences.