United States v. Hansen

HOLMES, Circuit Judge.

*1243 Louis Hansen, a taxpayer who ascribes to legal theories associated with sovereign-citizen and tax-protester movements, was indicted for tax evasion in violation of 26 U.S.C. § 7201 and tax obstruction in violation of 26 U.S.C. § 7212 (a). Before trial, Mr. Hansen purported to waive his right to counsel. The district court held a hearing to determine whether this waiver was made knowingly and intelligently. At that hearing, the district court asked Mr. Hansen, among other things, whether he understood he would be required to follow federal procedural and evidentiary…