Michael Minns is a tax defense attorney and an often-quoted IRS critic whose more successful case work against the IRS includes the aqcuittals of multiple American Airlines pilots who were charged of tax fraud by the IRS [1], and the historic appeal of James and Pamela Morans, who were cleared on all 64 charges of tax fraud.[2]. Minns has has been a frequent commentator on media stories about the tax code and the IRS [3] [4] [5], and has authored a published article on the concept of "willfulness" as it pertains to the intent to defraud the government. The legal concept of "willfulness" is a recurring and key issue in proving the guilt (or innocence) of those charged by the IRS with tax fraud and tax evasion.[6]