Brown (D) was charged with preparing false Income Tax returns. The Government's evidence included the testimony of IRS agent Peacock that between 90 and 95% of the returns prepared by D, which Peacock audited contained overstated itemized deductions. The testimony was offered for the sole purpose of proving the willfulness of D's actions. It was apparent, however, that Peacock's belief that D's actions were willful could not have been based solely on the returns themselves. The record indicates that she arrived at that belief through conversations with taxpayers on whose behalf the returns were prepared. D argued that her conclusions were formulated from out of court statements of taxpayers whose returns the agent had examined. D was convicted and appealed.

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