Whether, in a prosecution for aiding and assisting in the preparation or filing of false tax returns under 26 U.S.C. § 7206(2), the government is required to prove beyond a reasonable doubt that the accused voluntarily and intentionally violated a known legal duty as required by this Court's precedent; or whether, as the Eleventh Circuit held here, it is sufficient if the government merely proves a lower mens rea standard by proving that the accused simply acted with the intent to do something the law forbids?

Whether, in a prosecution for aiding and assisting in the preparation or filing of false tax returns under 26 U.S.C. § 7206(2), the government is required to prove beyond a reasonable doubt that the accused voluntarily and intentionally violated a known legal duty as required by this Court's precedent; or whether, as the Eleventh Circuit held here, it is sufficient if the government merely proves a lower mens rea standard by proving that the accused simply acted with the intent to do something the law forbids?