The following excerpt is from U.S. v. Bishop, 291 F.3d 1100 (9th Cir. 2002):
And I want to make clear the defendants have no burden in this case. They did not have the burden of showing good faith. The government had the burden of showing willfulness, and the government has met that burden of showing willfulness beyond a reasonable doubt despite the evidence that the defendants each presented regarding good faith reliance....
The term "willfully," I find, is what has been referred to in Cheek v. United States ....
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