1. Does this Court's decision in Cheek v. United States, 498 U.S. 192 (1991), require a court to apply a subjective standard in determining whether there was evidence of full disclosure to support a reliance on a tax professional jury instruction in a criminal tax case?

2. Is a defendant entitled to a jury instruction on the defendant's reliance on a tax professional theory of defense in addition to a standard instruction on specific intent, where there is an adequate foundation for the defense?

Whether a subjective standard must be applied in determining whether there was evidence of full disclosure to support a reliance on a tax professional jury instruction in a criminal tax case