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Defining Willfulness: The Role of the Defendant’s Ability to Pay in United States v. Easterday

In United States v. Easterday, the Ninth Circuit affirmed the district court’s refusal to give an “ability to pay” instruction in the criminal tax prosecution of Jack Easterday for “willful failure to pay over employee payroll taxes” in violation of section 7202. ...

Elizabeth M. Fialkowski

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