102857P.pdf   09/09/2011  United States  v.  Brian Ellefsen
   U.S. Court of Appeals Case No:  10-2857
                          and No:  10-2858
   U.S. District Court for the Western District of Missouri - Joplin   
   [PUBLISHED] [Wollman, Author, with Melloy, Circuit Judge, and
   Miller, District Judge]
   Criminal case - criminal law. Brady argument rejected as the defendants
   failed to show undisclosed IRS internal documents contained material
   information, the disclosure of which would have affected the outcome of
   their trial; no error in allowing government witness to testify that funds
   flowing through the tax avoidance scheme constituted constructive
   dividends; while additional cross-examination into the witness's testimony
   should have been allowed under Rule 611(c), the error was harmless
   beyond a reasonable doubt; no error in excluding defendants' proposed
   expert testimony as it had only slight relevance to the issue of the
   defendants' willfulness and would have sidetracked the proceedings;
   evidence was sufficient to show defendants willfully used a series of
   offshore and domestic entities to avoid paying federal income tax; the
   district court did not err in calculating defendants' restitution.