Does a defendant have reason to believe their actions were unlawful?
MultiRegion, United States of America
The following excerpt is from U.S. v. Spurrier, 930 F.2d 30 (9th Cir. 1991):
In addition, defendants argue that although this court in United States v. Russell, 804 F.2d 571 (9th Cir.1986) found a similar tax shelter scheme illegal, it did not do so until two years after the alleged conspiracy. Thus, they claim, defendants had no reason to believe their actions were unlawful.
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