1. Defendants requested instructions on their theory
of defense, that they relied in good faith upon the
professional advice of their CPAs when preparing
the tax returns at issue in this matter, tax return
preparers who publicly marketed themselves as
being able to reduce taxes dramatically, when all
returns were prepared, signed and submitted by
the tax return preparers. May a court refuse to give
an instruction concerning a criminal defendant's
theory of defense by asserting that the instruction
concerning the elements of the charged crime
encompasses the defendant's theory of defense?

2. May a search warrant—which did not limit the
search by time or criminal activity, which sought
twenty broad categories including "all electronic
devices," and which the district court recognized
afforded discretion to the officers executing the
search—be upheld based on modifications imposed
by the district court after the search was conducted
and all the seized items analyzed?

3. Does an individual have standing under the Fourth
Amendment to contest the search of a house in
which he stored personal and business effects in
closed containers outside of commons areas,
maintained a bedroom, and occasionally slept in; he
was a specific target of the search warrant; and his
personal and business effects were seized?

Whether a court must instruct the jury on a criminal defendant's good-faith reliance on professional tax advice as a defense, the scope of discretion afforded to officers executing a search warrant, and standing to contest a Fourth Amendment search