United States v. Brown

Brown (defendant), a tax preparer, was convicted of accounting fraud after a witness testified that 90-95% of roughly 160 tax returns he prepared were fraudulent. Brown challenged the admission of that testimony as improperly relayed hearsay going to his intent to commit fraud, and also invoked Rule 404(b)'s bar on character evidence of similar crimes.

Whether the witness's testimony about the fraudulent nature of the defendant's other tax returns was improperly admitted.