Why the criminal complaint helps you from being indicted:
"Because failure to file and failure to pay are specific intent crimes, negligence is a defense to willfulness. The government must prove that the defendant acted purposefully
as distinguis[h]ed from inadvertently, negligently, or mistakenly." United States v. Collins, 457 F.2d 781, 783 (6th Cir 1972); United States v. Matosky, 21 F.2d 410, 413 (7th Cir. 1970).
