United States v. Kupfer (Elizabeth)

BACHARACH, Circuit Judge.

Ms. Elizabeth Kupfer and her husband jointly filed federal income taxes for 2004-2006, but failed to report over $790,000 in gross income. The government charged Ms. Kupfer with three counts of tax evasion, one for each tax year. See 26 U.S.C. § 7201. She admitted that she had failed to report a substantial amount of gross income, but denied that her under-reporting was willful. The jury disagreed and found Ms. Kupfer guilty on each of the three counts. Convicted and sentenced to three years in prison; Ms. Kupfer appeals based on three issues.

I. The Three Issues on…