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U.S. v. KNOTTNERUS

No. 97-2939.

139 F.3d 558 (1998)

UNITED STATES of America, Plaintiff-Appellee, v. Cornelius KNOTTNERUS, Defendant-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided March 17, 1998.

Rehearing and Suggestion for Rehearing Denied April 15, 1998.

Attorney(s) appearing for the Case

James M. Conway, Office of the United States Attorney, Criminal Division, Chicago, IL, Gil M. Soffer (argued), Office of the United States Attorney, Chicago, IL, for Plaintiff-Appellee.

Daniel T. Hartnett (argued), Martin, Brown & Sullivan, Chicago, IL, for Defendant-Appellant.

Before FLAUM, EASTERBROOK, and DIANE P. WOOD, Circuit Judges.

Rehearing and Suggestion for Rehearing En Banc Denied April 15, 1998.

FLAUM, Circuit Judge.

By his own admission, Cornelius Knottnerus "fell under the influence of a tax protest movement" and failed to file income tax returns for the years 1987 through 1993. He tried to avoid criminal punishment for this misdeed by seeking the protections of the Internal Revenue Service's Voluntary Disclosure Policy in 1993. Under this program,

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