This section contains the nature of the case and procedural background.

Pomponio (D) and another were convicted of falsifying their tax returns. They reported taxable dividend payments to themselves as loans and then claimed partnership losses as deductions with knowledge that these deductions were attributable to the corporation. The jury was instructed that D was guilty only if he signed the returns knowing them to be false and did so willingly. 'Willingly' was defined as intentionally and with a bad purpose. The trial judge also instructed the jury that this motive was not relevant except in its relationship to intent. D was convicted and appealed. The court of appeals reversed; an evil motive meant more than the specific intent to commit a crime. The Government (P) appealed. The Supreme Court granted certiorari.

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