[rmnunez]

I think the "ignorance of the law" ought to be a defence when it comes to the rather complex and lengthy US Tax Code, particularly if its violators are being prosecuted on criminal charges. To be criminally liable in such a case would require intentional, knowing and intelligent violation, but what I've read of the Tax Code is difficult to understand, requires cross reference to arduous definitions and consideration of numerous former determinations before one could figure out the applicable rule, this is why people resort to tax accountants and other specialists. In these circumstances, to have interpreted the Code erroneously does not seem criminal.