1. Whether the lower courts violated, Napue v. Illinois, 360 U.S. 264, 269 (1959), thus effectuating a constitutional violation below and establishing a new precedent permitting the IRS to require trustees to report on the schedule C of their personal income tax returns, the year-end balances held in trust — funds that are legally owed to third parties; thus, resulting in the imposition of an additional tax not authorized by, nor contemplated under, the Internal Revenue Code.

2. Does a split among the circuits call for a review of this Honorable Court, more specifically was the Petitioner's right to a fair trial violated when the prosecution introduced evidence of a prior professional discipline under Federal Rule of Evidence 404(b), despite the lack of a clear nexus to the charged conduct, thereby inviting the jury to convict based on impermissible character inferences.

Whether the IRS can require trustees to report year-end trust balances on personal income tax returns in violation of Napue v. Illinois and the Internal Revenue Code